3 As recognized by the Philadelphia Business Journal. For more information, see the Accolades page.
Sage Financial Group, Inc. (“Sage”, “we,” “us,” or “Company”) is strongly committed to respecting and protecting your privacy. Please carefully read the following Privacy Notice (“Notice”). To ensure your privacy, the information we collect from visitors to this Website (the “Site”) is used only in the manner and for the purposes described in this Notice.
The purpose of this Notice is to explain the type of information that the Company collects, what we do with that information, and with whom the Company shares this information. Anyone who provides personally identifiable information (“Personal Information”) or any other information to the Company consents to the collection, use, and disclosure of such information under the terms of this Notice. This Notice applies to individuals who browse and use our Site (“Visitors”).
Information We Collect from Visitors to our Site
When a Visitor signs up for our newsletter ‘Sage Investment Perspective’ on the “Contact Us” page, the only Personal Information we collect is first name, last name, and email address, which is voluntarily submitted by you. When a Visitor sends an email to Sage via the Site, the Personal Information we collect is your email address and any other information voluntarily submitted by you in the message section of the email.
When you access sagefinancial.com (or any web site), your web browser may automatically send information about your computer, e.g., your User agent and IP address, if your computer enables cookies. Cookies are small text files that are stored in your computer’s memory and hard drive when you visit certain web pages. We do not store this information, nor do we run third party browser cookies on our Site.
Internet sites that you link to from the Site may contain privacy provisions that differ from the provisions of our Privacy Notice. To ensure your privacy is protected, we recommend that you review the privacy statements of other Internet sites you visit.
How We Use the Information We Obtain
We may use your Personal Information to email our monthly newsletter and other related communications. Once you have requested information from us, we may communicate with you to provide additional information related to your initial information request. However, we will never ask you to send Personal Information such as account or Social Security numbers by non-secure email. You have the right to unsubscribe when you have provided your consent to receive these communications by clicking on the embedded link to unsubscribe.
We may use aggregated Site data to ensure that content from our Site is presented in the most effective manner and tailored to our Visitors’ interests and the manner in which our Visitors browse our Site.
We will only use your Personal Information for the purposes articulated herein, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
How We Protect Personal Information
We take seriously the obligation to safeguard your Personal Information. We maintain physical, electronic, and procedural safeguards to protect against unauthorized access to your Personal Information. Details of our technology security measures are set forth in our privacy and cybersecurity policies. We endeavor to restrict access to Personal Information about you to those employees of Sage and service providers who need access to that information. All of our employees and service providers are required to maintain the confidentiality of all Personal Information. Employees are educated about the importance of privacy in accordance with our Code of Ethics.
Information We Share
We do not disclose Personal Information we obtain about you through the Site, except as described in this Privacy Notice. Sage may disclose your information: (1) to our affiliates, individuals and/or entities not affiliated with Sage in furtherance of providing services to you in response to your contact with us; (2) when required to do so by judicial or regulatory process; or (3) when we are otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations, or when you have authorized us to share information.
In addition, we may share anonymous/aggregate information with third parties, such as service providers, for any purpose.
We will not disclose or transfer Personal Information to third parties for the purposes of marketing. The disclosure of your information for processing and/or transmittal by Sage in furtherance of your relationship with us shall be deemed as having been automatically authorized by you with respect to the corresponding nonaffiliated third-party service provider.
Updates and Contact Information
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our information handling practices. We will post the updated version on the Site and indicate when it was most recently updated. We urge you to check this Site periodically to review the most recent Privacy Notice. Your continued use of the Site following any changes to this Privacy Notice will constitute your acceptance of the changes. If you have any questions or comments about this Privacy Notice, please contact John Sion, Chief Compliance Officer, at JSion@sagefinancial.com.
This Privacy Notice Supplement (“Supplement”) should be read in conjunction with the Sage Privacy Notice. This Supplement applies to the extent that EU Data Protection Legislation governs the processing of personal data by an Authorized Entity or to the extent that a data subject is a resident of the UK, the European Union (“EU”) or the European Economic Area (“EEA”). If this Privacy Notice applies, the data subject has certain rights with respect to such personal data, as outlined below.
For purposes of this Supplement, “EU Data Protection Legislation” means all applicable legislation and regulations relating to the protection of personal data in force from time to time in the EU, the EEA, or the UK, including (without limitation): the Data Protection Directive (95/46/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, or any other legislation which implements any other current or future legal act of the European Union concerning the protection and processing of personal data (including Regulation (EU) 2016/679 (the General Data Protection Regulation) and any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing.
As defined in this legislation, Sage is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Information about you. We are required under data protection legislation to notify you of the information contained in this Notice.
Information We Share
In addition to the permissible forms of sharing noted above, where the Personal Information of EU Visitors is processed by third parties outside the UK and EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by law, including where applicable, the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission) or certified under the EU-US Privacy Shield framework.
We reserve the right to transfer Personal Information we have about you if we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution, or liquidation). We may transfer the Personal Information we collect 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. When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Notice.
We retain your Personal Information for a period of at least five years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended (or if later the date on which the last transaction was completed or the last entry to the record was made). Thereafter, Sage will delete (or otherwise erase, de-identify or equivalent) any such personal data except as required or permitted by applicable law or regulation.
Your Rights and Choices
If you are located in the EEA, you have certain rights relating to the Personal Information we hold in accordance with and subject to GDPR and applicable privacy laws to:
- Check whether we hold Personal Information about you and to access such data (in accordance with our policy);
- Have a copy of the Personal Information we hold about you provided to you or another controller where technically feasible;
- Request the erasure of your Personal Information;
- Request the restriction of processing relative to your Personal Information; and
- Where you have provided Personal Information voluntarily, or otherwise consented to its use, the right to withdraw your consent.
How to Contact Us
If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact John Sion, Chief Compliance Officer, at JSion@sagefinancial.com.
Amended and Effective: This Notice took effect on June 27, 2018.
Terms and Conditions
Welcome to https://www.sagefinancial.com/. The information offered by Sage Financial Group (“Sage”), on this website (the “Site”) is subject to certain terms and conditions (the “Terms and Conditions”). These Terms and Conditions apply to all users. By entering the Site or by transmitting any information to the Site you acknowledge and agree to all of the Terms and Conditions. Please read them carefully. If you do not agree to the Terms and Conditions, please do not use the Site. Any use of the Site in a manner inconsistent with these Terms and Conditions is deemed unauthorized access and may subject the user to civil or criminal penalties. We reserve the right to revise these Terms and Conditions at any time and for any reason, without notice or obligation, by updating this posting. Your continued use of the Site following the posting of any changes to the Terms and Conditions will mean that you accept such amendments. We strongly recommend that you periodically visit this page of the Site to review the Terms and Conditions.
Use of Website
This Site is limited to the dissemination of general information pertaining to Sage’s advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Sage’s Site on the Internet should not be construed by any consumer and/or prospective client as Sage’s solicitation to affect, or attempt to affect, transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Sage with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.
Sage does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Sage’s Site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
Restricted Use of Site Materials
Sage grants you a limited license to access and make use of the Site. For your personal use only, you may print copies of the information from the Site and you may store information from the Site on your own computer. You may not modify the Site, or any portion thereof, for any reason. Any unauthorized use terminates the permission or limited license granted by Sage. Sage reserves all other rights.
Sage Financial Group (“Sage”), located in West Conshohocken, Pennsylvania, is an investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”). Registration as an investment advisor does not imply a certain level of skill or training. Sage and its representatives are in compliance with the current filing requirements imposed upon SEC registered investment advisors by those states in which Sage maintains clients. Sage may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements.
For information pertaining to the registration status of Sage, please contact the SEC or the state securities regulators for those states in which Sage maintains a notice filing. A copy of Sage’s current written disclosure statement discussing Sage’s business operations, services, and fees is available from Sage upon written request.
Not Investment Advice
Certain portions of Sage’s Site (i.e., newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Sage’s (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Sage or from any other investment professional. Sage is neither an attorney nor an accountant. No portion of the content on this Site should be interpreted as legal, accounting or tax advice.
Use of Third Party Rankings
Neither rankings and/or recognition by unaffiliated rating services, publications, or other organizations, nor the achievement of any designation or certification, should be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if the Registrant is engaged, or continues to be engaged, to provide investment advisory services. Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser. Rankings are generally limited to participating advisers. No ranking or recognition should be construed as a current or past endorsement of the Registrant by any of its clients. The Registrant did not pay a fee to disseminate this information, although these publications have a financial incentive (paid subscriptions) to publish such information, and the Registrant may pay a fee to subscribe to such publications. The Registrant’s Chief Compliance Officer, John J. Sion, remains available to address any questions regarding rankings and/or recognitions, including providing the criteria used for any reflected ranking.
Linking, Posting and Transmitting
Although Sage provides the information accessible on the Site for your personal, non-commercial use, Sage retains all property rights, including, without limitation, property rights under U.S. and international copyright law, to all such information. Without the prior express written permission of Sage or as set forth under “Restricted Use of Site Materials” above, you MAY NOT do any of the following: (A) hyperlink to the Site, whether to its homepage or to an interior page; (B) include information from the Site on another site, on a server computer, or in documents; (C) modify or re-use the information from the Site; or (D) transmit any commands, codes or information to the Site, with the exception of those commands necessary to view the Site. Sage reserves all other rights.
Although Sage, or other parties involved in creating, producing, or delivering the Site, may monitor or review any transmissions to the Site or to Sage personnel, Sage and such other parties assume no responsibility or liability that may arise from the content thereof, including, without limitation, claims for defamation, libel, slander, obscenity, pornography, profanity, or misrepresentation.
Each client and prospective client agrees, as a condition precedent to his/her/its access to Sage’s Site, to release and hold harmless Sage, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from Sage.