Effective Date: January 1, 2023
How Do We Collect Personal Information
- From you. We may collect personal information and other information that you provide when you use our Services, register with LPL Financial online, interact with our affiliated Advisors, or otherwise communicate with us.
- From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.
- From third parties and publicly available sources. This includes personal information we collect from public sources including, but not limited to, websites that enable social sharing, social media sites, and from our Service Providers, Third Parties, vendors and suppliers, our affiliates, or other individuals and businesses.
- From you in person. This includes information you may give one of our Advisors if you meet with them in person.
Types of Personal Information We May Collect from You
Depending on how you interact with us and our Services, we may collect the following information:
- Contact information such as name, email address, zip code, phone number, and home address.
- Biographical and identifying information such as date of birth, location, and Social Security Number.
- Financial information such as your income, investment preferences, accounts with us and other financial institutions, as well as other financial details.
- Internet usage information such as browsing history, search history, information regarding your interaction with our online services or advertisements, IP address, browser type, and clickstream data.
- Device information. Such as browser or device model and settings, operating system, and unique identifiers, and the version of the app you’re using.
- Inferences such as inferences drawn from any of the personal information we collect to better understand your preferences.
- Account information such as information you provide when you create an account, like username and password.
- Transaction information such as information needed to complete your transactions, such as your bank account information, and your transaction history.
If you submit any personal information relating to other people to us, such as information about other account holders, family members or beneficiaries, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
How We May Use Your Personal Information
We may use information you provide us through our online services to:
- Provide, market, and develop our products and services. LPL Financial collects information to provide our services, maintain our websites and mobile applications, and better understand the interests of our clients and investors who use our services and products.
- Process transactions and administer your account. We may use your information to process your transactions and requests.
- To process your employment application. We may use your information to process employment applications, including verifying statements made on your application (e.g., credit and employment history), performing background and credit checks.
- Communicate with you. We may use your information to respond to your inquiries and send you communications regarding our products and services.
- Develop new products and services and quality assurance. We may use personal information to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
- Verify your identity and verify our records. We may use personal information to verify your identity for the purposes of responding to a request regarding your personal information that you make. This information may also be used to verify our own records for accuracy.
- Debugging and performance of systems. We may use your personal information to secure our online services including our network and websites and to debug our online services. We may also use it to diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services
- Comply with law. We may use personal information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigation.
- Internal business purposes. We may use personal information for our internal business purposes, such as data analysis, audits, and enhancing our Services. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our Services to you.
How We Disclose Personal Information
We may disclose personal information in the following ways:
- Service providers. We may provide personal information to vendors, contractors, business and service partners, or other third parties who provide services to us including data storage firms, payment companies, technology suppliers, technology services, customer service, risk solution providers, analysis firms, fraud prevention companies, advertisers, marketers, and others.
- Collaborators and advisors. We may disclose personal information with collaborators with whom we jointly develop or promote our services, such as our Advisors.
- Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
- At your direction. We may disclose your personal information at your direction or with your consent.
- Product sponsors. If you are an Advisor, we and our partners may sell your personal information to product sponsors for those product sponsors’ own marketing efforts and purposes.
- Aggregate data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.
- In connection with a merger, acquisition, or business transfer. If LPL sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a reorganization, merger, or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), LPL may transfer or disclose your information to the party or parties involved in the transaction as part of that transactio
You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.
Links to Third-Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.
Advertising and Opt-Out Disclosures
When you use our Services, our third-party advertising partners, social media providers and analytics providers may collect personal information about your online activity on our Services and on third party websites.
These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.
Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history.
We and our partners may use also use these technologies to gather personal information about how you view and use our Services and content, and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.
Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies such as cookies. To find out more about cookies, visit www.aboutcookies.org. Also, certain versions of the Android operating system allow you to “Opt-out of Ads Personalization” in the system settings. Options you select are browser and device specific.
Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT or a common definition of “tracking,” we do not currently respond to the DNT signal on our websites. We do, however, honor other global privacy preferences when required by law.
Your Marketing Preferences
We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly.
There are certain service notification and other non-promotional emails that you may not opt-out of, such as notifications of changes to our Services or policies.
It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from LPL Financial but you suspect may be from another source and might be fraudulent, please email us at PrivacyResponseTeam@LPLFinancial.com or call the Incident Hotline at (866) 578-7011.
California Consumer Privacy Act Notice
What We Collect
In the past 12 months, we have disclosed (or have enabled you to disclose) and have collected the following categories of Personal Information. Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 16 years of age.
|Category||Categories of Parties to Whom Information Is Disclosed||Categories of Third Parties to Whom Information Is Sold and/or Shared|
|Identifiers and contact information, including first and last name, email address, phone number, home address, driver’s license number, military and/or veteran status.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers. If you are an advisor, to our product sponsors.|
|Identifiers such as username, third party service ID, IP address, unique device identifier, advertising identifier, device serial number.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers.|
|Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, and clickstream data.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers.|
|Commercial information, including financial information.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Analytics providers, advertising providers, and lead generation providers|
|Demographic information, including your gender, age, date of birth, citizenship status.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers.|
|Visual information, such as your profile picture||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers.|
|Inferred information, such as non-precise geolocation information, approximate location as inferred from IP address.||Service providers, customer service providers, and other providers or partners that support||Advertising providers, analytics providers.|
|Other information you may share if you use social features when accessing our Services, including the organizations, links, and other information included on your social profile page.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics providers.|
|Sensitive Personal Information, such as social security number, trade union membership, Advisor’s racial or ethnic origin.||Service providers, customer service providers, and other providers or partners that support our operational business purposes, such as Advisors.||Advertising providers, analytics provides.r|
We may use this Personal Information for the following purposes, including commercial purposes:
- To operate, manage, and maintain our business;
- To provide our products and services;
- To accomplish our business purposes and objectives, including:
- developing, improving, repairing, and maintaining our products and services;
- personalizing, advertising, and marketing our products and services;
- conducting research, analytics, and data analysis;
- maintaining our facilities and infrastructure;
- quality and safety assurance measures;
- conducting risk and security controls and monitoring;
- detecting and preventing fraud;
- performing identity verification;
- performing accounting, audit, and other internal functions;
- complying with the law, legal process, and internal policies;
- maintaining records; and
- exercising and defending legal claims.
Sources of Personal Information
We collect this Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website or apps); joint marketing, co-branding, co-promotional, or advertising partners; Advisors; and sources of demographic and other information. The sources of personal information collected are noted in the “How Does LPL Financial Collect Information” and “What Information does LPL Financial Collect” sections above.
Rights and Choices Available to California Residents
If you are a California resident, you may have the following rights with respect to any information about you that constitutes “Personal Information” under California law:
- Request to Know and Access Your Personal Information: You may access the information we maintain about you using the methods provided below. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Request to Delete Your Personal Information: You may request that we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, as permitted by applicable law, we may retain your information in our business records. You may submit a deletion request using the methods provided below. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Request to Opt-Out of “Sale” and Certain Sharing Practices: You have a right to opt-out of the sale or share of your personal information, as defined by California law. In order for you or your authorized agent to exercise this right, please visit our “Do Not Sell or Share My Personal Information” page. We also honor global opt-out signals when required by applicable law. We process opt-out preference signals in a frictionless manner.
- Request Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate personal information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Non-Discrimination: We will not discriminate against you, in terms of price or services that we offer, if you submit one of the requests listed above.
- Limit the Use of Sensitive Personal Information. You have a right to limit the use of your sensitive personal information. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
California consumers may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California consumer to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these right digitally. If you are an authorized agent trying to exercise rights on behalf of a LPL consumer, please contact us at the contact information below with supporting verification information, proof that you have access to the consumer’s interface, and proof of your own identity.
To Exercise Your Rights
In order to exercise your Right to Opt-Out of the Sale or Sharing of your Personal Information, please visit our “Do Not Sell or Share My Personal Information” page.
In order to exercise your Right to Limit the Use of Your Sensitive Personal Information, please complete this page here. Please note that the information in this page is necessary for us to correctly identify you and process your request.
In order to exercise your other rights described above, please navigate to our online web portal available at privacy.lpl.com
or call (888) 531-0080. We may need to obtain information about you or your specific request in order to verify your identity and respond.
Updating and Correcting Your Personal Information
Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, please feel free to also contact your financial professional or LPL Financial at (800) 558-7567.
Shine the Light Disclosure
We do not share personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by sending an email to Privacy@LPLFinancial.com or by sending a letter to LPL Financial, Attn: Privacy Office, 1055 LPL Way, Fort Mill, SC, 29715. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.
Storage and Protection of Personal Information
We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of personal information. Procedurally, LPL employees are bound by, and held accountable to, a code of conduct and policies regarding confidentiality and the treatment of client information. Furthermore, only those LPL employees who require access to your personal information in order to provide customary services (investment, administrative, legal) to your account are granted access to your personal information. Additionally, LPL has a dedicated group that designs, implements and provides oversight of information security. We also monitor our systems infrastructure in order to detect weaknesses and potential intrusions.
Physically, LPL has policies that require our employees to store and destroy documents containing your personally identifiable information in accordance with applicable laws, federal guidelines and industry best practices.
Technologically, LPL uses methods such as encrypting files, utilizing firewalls to prevent unauthorized access to information, restricting access to client information to prevent removal of information from the firm, and masking of data on computer screens to protect your personal information.
In order to help secure personal information collected from you as an LPL Financial online services user, including sensitive financial data, the information is protected by SSL encryption when it is exchanged between your web browser and LPL Financial online services. However, the internet is not a fully secure environment, and we cannot ensure or warranty the security of any information transmitted to or generated by LPL Financial in connection with LPL Financial online services. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. For more information on protecting your electronic information, please visit our Privacy/Security page. You agree that you are responsible for any additional verification procedures and security you deem necessary.
While we take the aforementioned steps to secure our websites and applications, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet. LPL Financial cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to LPL Financial, you do so at your own risk.
Notice to Persons Accessing the LPL Financial Site Outside the United States
If you access the LPL Financial online services outside the United States, any information you provide to us through the LPL Financial online services will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.
Contacting Us About Privacy Questions