SILVER SOLUTIONS
For brokerage firms and related service providers seeking to significantly reduce operating expenses and enhance client experiences, Silver delivers the full spectrum of regulatory cost basis processing solutions including its best-in-class Silver Cost Basis software and onshore business process outsourcing (BPO) services.
Unlike legacy cost basis vendors or homegrown solutions, Silver Cost Basis ensures regulatory compliance at a demonstrably lower total cost of ownership (TCO).
Unlike legacy cost basis vendors or homegrown solutions, Silver Cost Basis ensures regulatory compliance at a demonstrably lower total cost of ownership (TCO).
For digital currency brokers, exchanges, and related service providers seeking a reputable crypto tax solution to enhance client experiences and prepare for ever-increasing regulatory scrutiny, Silver delivers the full range of cost basis processing using its modern 24×7 real-time Silver Cost Basis solution.
Unlike competitive start-up or homegrown cost basis solutions, Silver Cost Basis extends its experience and leadership position in securities cost basis processing to the cryptocurrency industry.
Unlike competitive start-up or homegrown cost basis solutions, Silver Cost Basis extends its experience and leadership position in securities cost basis processing to the cryptocurrency industry.
For leading-edge wealth technology platform owners seeking to deliver truly differentiated client experiences, Silver offers its ultra-scalable cloud-based Wealth Harmony solution, featuring the first-of-its-kind Unified Data foundation with essential third-party integrations and numerous plug-and-play applications.
Unlike competitive “all-in-one” or homegrown solutions, Wealth Harmony empowers investment firms and related service providers to quickly and cost-effectively grow their businesses by offering their own unique wealth technology platforms.
Unlike competitive “all-in-one” or homegrown solutions, Wealth Harmony empowers investment firms and related service providers to quickly and cost-effectively grow their businesses by offering their own unique wealth technology platforms.
SILVER NEWS
February 2021 — Silver announced the additions of Jean Saladino and Patricia Neil to the team. In spite of the challenges brought on by the global pandemic over the past year, Silver experienced record-breaking growth in its cost basis and wealth technology client bases and is now expanding its leadership team to move the company to the next level…
October 2020 — Silver announced numerous improvements to its best-in-class cost basis platform, further reducing total cost of ownership and enhancing client experience for cost basis processing and tax reporting. Silver enhanced its fully automated corporate action processing, detailed fixed income amortization and accretion statements, and comprehensive modern API for real-time access to cost basis data…
July 2020 — There is no doubt that these last few months have been exceptionally disruptive. In one way or another, we have all been forced out of our comfort zones. As we work together to overcome the great adversity of these uncertain times, I sincerely hope that each of us can also discover a silver lining…
A message from our CEO…
“It’s only after you’ve stepped outside your comfort zone that you begin to change, grow, and transform.” — Roy T. Bennett
There is no doubt that these last few months have been exceptionally disruptive. In one way or another, we have all been forced out of our comfort zones. As we work together to overcome the great adversity of these uncertain times, I sincerely hope that each of us can also discover a silver lining.
Personally, I am finding much more time to connect with my wife and four children. Regular family dinners, movie nights, driveway pickleball tournaments, and an organized garage are welcome changes – particularly as my kids prepare to leave for their colleges and ballet school in Austin, Boulder, Miami, and San Francisco. We are making the most of this extra time together.
Professionally, thanks to the fortitude and efforts of the entire Silver team, our business is also experiencing a bright side during these challenging times. Silver Cost Basis is seeing unprecedented interest from firms seeking to transform their legacy cost basis operations by significantly reducing operating expense and enhancing the client experience. Similarly, Silver Wealth Technologies is growing exponentially as wealth tech platform owners are leveraging Wealth Harmony to quickly and cost-effectively grow their businesses.
Like all of you, I look forward to better days ahead. Stay healthy!
Blake Henry, CEO
Silver News…
Voyager partnered with Silver Cost Basis to deliver year-end cryptocurrency gain/loss statements to its customers
Silver’s Neal Ruskin invited to discuss tax reporting challenges and solutions at SIFMA’s Global Tax Reporting Symposium in October
A message from our CEO…
“It’s only after you’ve stepped outside your comfort zone that you begin to change, grow, and transform.” — Roy T. Bennett
There is no doubt that these last few months have been exceptionally disruptive. In one way or another, we have all been forced out of our comfort zones. As we work together to overcome the great adversity of these uncertain times, I sincerely hope that each of us can also discover a silver lining.
Personally, I am finding much more time to connect with my wife and four children. Regular family dinners, movie nights, driveway pickleball tournaments, and an organized garage are welcome changes – particularly as my kids prepare to leave for their colleges and ballet school in Austin, Boulder, Miami, and San Francisco. We are making the most of this extra time together.
Professionally, thanks to the fortitude and efforts of the entire Silver team, our business is also experiencing a bright side during these challenging times. Silver Cost Basis is seeing unprecedented interest from firms seeking to transform their legacy cost basis operations by significantly reducing operating expense and enhancing the client experience. Similarly, Silver Wealth Technologies is growing exponentially as wealth tech platform owners are leveraging Wealth Harmony to quickly and cost-effectively grow their businesses.
Like all of you, I look forward to better days ahead. Stay healthy!
Blake Henry, CEO
Silver News…
A message from our CEO…
Silver’s corporate vision ~ Financial Independence For All ~ The Bruce Williams Show on the radio. It led me to start this company in 1991. Today, it motivates the entire Silver team to deliver on our corporate mission to enable secure and timely access to trusted financial information. Here is how we are doing it:
- The “race to zero” trading commissions is forcing brokerage service providers to reduce costs and scale their operations. Last year, our clients converted millions of investment accounts from competitors’ legacy cost basis systems onto our modern Silver Cost Basis solution, dramatically improving their operational efficiencies and saving millions of dollars each year.
- Advisory fee compression and the growth of digital wealth solutions are driving wealth managers and their technology partners to do more for less. Last year, Silver launched Wealth Harmony – the first-of-its-kind, foundational wealth data platform – to maximize operational efficiencies, deliver value-add analytics and functionality, and turbocharge our clients’ unique wealth management solutions.
- Increasing regulatory scrutiny around the emerging cryptocurrency asset class is compelling digital currency brokers, exchanges, and platform providers to step up their compliance efforts. Silver Cost Basis supports our clients by providing fully compliant processing for every cryptocurrency event, including coin/fiat trades, coin/coin trades, payments, transfers, and income from hard forks, airdrops, mining, staking, and stablecoin interest.
It is often said that change brings opportunity, and there is certainly no shortage of change in the investment services industry. I’m eager for Silver and our clients to capitalize on those opportunities in 2020. Thanks!
Blake Henry, CEO
Silver News…
A message from our CEO…
Things are not always what they seem. Plato’s well-known quote was the theme of Silver’s recent client appreciation event in New York City where our clients, partners, and employees enjoyed a memorable evening with great company and world-class illusionist Alex Voz. It is no exaggeration that Alex transformed a room full of skeptics into believers.
We regularly face a similar challenge at Silver. Our clients seek to grow their businesses by improving customer experience, increasing operational efficiency, and lowering costs. Although Silver’s comprehensive business & technology solutions (which are designed to achieve all of these client objectives) are initially met with skepticism, the Silver team consistently delivers success for our clients (on-time and within budget). This is why clients choose Silver!
Blake Henry, CEO
Silver News…
Silver Cost Basis and Sovos Partner to Offer End-to-End Tax Information Reporting for Cryptocurrency
Harmony, Silver’s Unified Data Solution, Enables Efficient, Consistent, and Secure Digital Wealth Management Platforms
Silver is a proud sponsor of the SIFMA Global Tax Reporting Symposium in New York City (October 23-24)Why wait?
CONTACT USSILVER TEAM
As Managing Partner (Business), Blake is responsible for establishing and enriching client relationships, identifying opportunities for partnerships and growth, and overseeing all aspects of Silver’s business operations. Since founding the company in 1991, Blake has successfully led development and deployment of numerous enterprise-scale brokerage processing solutions. Prior to founding Silver, he was a Computer Programmer for IBM Corporation and CACI Field Services. Blake earned his B.S. in Economics at the Wharton School of the University of Pennsylvania with concentrations in Marketing and Decision Science.
As Managing Partner (Product), Neal is responsible for Silver’s suite of investment services processing software. An acknowledged expert in cost basis portfolio accounting and investment tax reporting, he guides Silver’s interpretation of IRS regulations and related statutes, serves as an industry thought leader, and is a frequent speaker at various tax conferences. Prior to joining Silver, he served as Chief Enterprise Architect at TD Ameritrade and Technical Director at CheckFree Investment Services (now Tegra118). Neal earned his M.A. in Industrial Design and Human Factors from The Pratt Institute and his B.A. in Political Economics from Princeton University.
As Managing Partner (Technology), Rob is responsible for all technical aspects of Silver’s brokerage processing software and related infrastructure services. He heads a team of highly-skilled and experienced software development professionals in technical design, application architecture, research and development, software deployment, technical operations, and information security. Prior to joining Silver in 1999, Robert served in various technology positions with CheckFree Investment Services (now Tegra118), Prudential Investments, ILX Trading Systems (now Refinitiv), and Brown Brothers Harriman. Robert earned his B.S. in Computer Science from the State University of New York at Stony Brook.
The Silver team applies decades of securities industry and software development experience along with a passion for solving real-world problems to deliver cost-effective brokerage operations, cost basis reporting, and wealth management solutions for our clients.
SILVER MANAGEMENT GROUP OF COMPANIES
SILVER VISION
Financial
Independence
For All
SILVER MISSION
Enabling secure and timely access to trusted financial information
WE ARE SILVER
We deliver seamless, scalable business and technology solutions for investment services companies – Silver Solutions.
Our employees apply decades of securities industry and software development experience along with their passion for solving real-world problems.
Our strategic partners provide complementary services, software, and market data to enhance our solutions.
Our clients trust our deep knowledge of brokerage operations, cost basis reporting, and wealth management.
They value our understanding of their internal processes, systems, and environments.
And, they appreciate our adaptable software that integrates seamlessly with their technical infrastructure and scales to meet their specific business needs.
This is why clients choose Silver.
Why Silver Solutions are processing tens of millions of investment accounts and trillions in assets.
And why, after nearly 30 years in business, Silver continues to deliver superior value for our clients.
CONTACT INFO
JOIN SILVER'S MAILING LIST
Privacy Policy
Last updated: February 18, 2021 This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.Definitions
For the purposes of this Privacy Policy:- Account means a unique account created for You to access our Service or parts of our Service.
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Silver Management Group, Inc., 114 Rabbit Hill Road, Princeton Junction NJ 08550.
- Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Country refers to: New Jersey, United States
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
- Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
- Service refers to the Website.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Website refers to Silver Management, accessible from https://silvermanagement.com/
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:- Email address
- First name and last name
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
- Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/
- Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
- Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
- Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
- Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.- Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
CCPA Privacy
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months. Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.- Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A 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. Some personal information included in this category may overlap with other categories. Collected: Yes.
- Category C: Protected classification characteristics under California or federal law. Examples: 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). Collected: No.
- Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: No.
- Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No.
- Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes.
- Category G: Geolocation data. Examples: Approximate physical location. Collected: No.
- Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No.
- Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No.
- Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.
- Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA's scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:- Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.
- Indirectly from You. For example, from observing Your activity on our Service.
- Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.
- From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that We use to provide the Service to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:- To operate our Service and provide You with our Service.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
- To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Sale of Personal Information
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit. Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return. We may sell and may have sold in the last twelve (12) months the following categories of personal information:- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above categories with the following categories of third parties:- Service Providers
- Our affiliates
- Our business partners
- Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission. We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us. If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:- The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- 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
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:- By email: info@silvermanagement.com
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
Do Not Sell My Personal Information
You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us. The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.Contact Us
If you have any questions about this Privacy Policy, You can contact us:- By email: info@silvermanagement.com