Last updated: February 2022
Thank you for visiting https://fountainheadinvesting.com, one of the Fountainhead
websites, or using one of the apps or services, (together the “Site”) operated by
Fountainhead Consulting LLC. We provide this privacy policy (“Privacy Policy”) explaining
our online information practices and the choices you can make about the way your
information is collected and used at the Site.
1. Introduction
Fountainhead is a crowd-sourced content service website for financial markets. Our
services empower investors to make the best investing decisions by leveraging our
independent and balanced stock research, fundamental analysis tools, reliable news and
actionable market data.
For more information about us, please see the “About Fountainhead” section of our Site
at https://fountainheadinvesting.com/.
2. Personal Information Fountainhead collects
When you visit our Site or register for our products and services (including as a subscriber
or a contributor), Fountainhead collects personal information about you. We use this
personal information for the business purpose of providing our products and services, as
well as marketing our products and services to new and potential customers. This includes
providing you with personalized recommendations and customized content on our Site.
The categories of personal information we collect from users of and visitors to our Site
are:
• Identifiers: This includes, for example, your name, nickname, username, email
address,, phone number, postal address (including ZIP code), Internet Protocol
address, and cookies or other identifiers which we assigned to uniquely identify you
or which others assigned to uniquely identify you. We obtain this information when
you provide it to us or otherwise automatically in the course of your interactions with
our products and services.
• Demographic information / Characteristics of protected classifications under
California or federal law: This includes information such as age (including date of
birth). We may obtain this information when you provide it to us, for identification
purposes upon registering as a contributor.
• Commercial Information: This includes Stocks, ETFs and other securities in your
investment portfolio, your trading pattern, list of authors you follow, investment style
preference, broker information and payment information (including bank account
details, to enable payments to you and from you when you register as a subscriber
or contributors). We obtain this information directly from you or otherwise
automatically in the course of your interactions with our products and services.
• Internet or other electronic network activity information: This includes, for example,
device screen size, device type (unique device identifiers), browser information,
your interactions with our Site and preferred language used to display our Site. We
obtain this information automatically in the course of your interactions with our
products and services.
• Geo-location data: This includes your country location (based on your IP address).
We obtain this information when you provide it to us or otherwise automatically in
the course of your interactions with our products and services.
• Audio, Video and other Electronic Data: This includes audio, electronic, visual or
similar information such as chat and any interaction that you may have with us
(such as for customer service purposes) as well as your profile photo. It also
includes any information you submit in forums, chat or message boards, and
feedback or testimonials you provide about our products and services. We obtain
this information when you provide it to us or otherwise automatically in the course
of your interactions with our products and services.
• Professional or employment-related information: This includes your job title,
education information, CFA status, and other biographical information including
professional interests and areas of expertise. We obtain this information when you
provide it to us upon registering as a subscriber or contributor.
• Profiles and Inferences: This includes inferences drawn from any of the information
identified above to create a profile reflecting preferences, characteristics,
predispositions, behavior, and attitudes. We obtain this information automatically in
the course of your interactions with our Services.
The sources from which we collect personal information are:
• Directly from you: For example, when you create an account, make a purchase,
apply for or accept an employment position with us, etc.
• Directly and indirectly from an activity on our Site and other services.
• Service providers who provide services on our behalf such as those used to fulfil
orders, process your payments and requests, verify your information, monitor
activity on our products and services, provide analysis and analytics, maintain
databases, administer and monitor emails and marketing, administer and send
mobile messages, serve ads on this and other services, and provide consulting
services.
• Third party data providers.
From time to time, we may also receive personal information about you from third party
sources but only where these third parties have confirmed to us that they either have your
consent or are otherwise legally permitted or required to disclose your personal
information to us. We use this information to maintain and improve the accuracy of the
records we hold about you and to send you personalized content, such us showing you
articles and news about your preferred stocks, or articles by authors you follow. The
personal information we collect includes:
• Contact information
• Investment style and market preferences
3. How Fountainhead Uses Personal Information
We use personal information collected through our products and services, both
individually and combined together, for purposes described in this Privacy Policy or
disclosed to you in connection with our products and services. For example, we may use
your information to:
• Create your account
• Provide and deliver products and services you request
• Send you service-related information updates, alerts, and support and
administrative messages
• Send you marketing communications and personalized content such us showing
you articles and news about your preferred stocks, or articles by authors you follow
• Respond to your enquiries
• Enable you to send and receive messages to other registered users and
contributors, and post comments
• Carry out analytics and to improve the quality and relevance of our Site
• Survey your opinions through surveys or questionnaires
• Serve and measure the eZectiveness of advertising
• Protect the integrity of our products and services and enforce our Terms of Use and
other applicable terms, including to detect and prevent fraud and unauthorized
activities, to secure our systems and the services, and prevent activities that may
violate our policies or be illegal
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal
activity, and prosecute those responsible for that activity
We may use personal information we collect from or about you to create aggregated or deidentified data that does not specifically identify you.
4. Personal Information Fountainhead discloses
We share personal information with other Fountainhead companies who help us to provide
you with products and services.
We also share personal information with third parties for the business purposes of
providing our products and services, and marketing our products and services to existing
and potential customers. The categories of these third parties with whom we share
personal information are:
• Hosting and infrastructure providers;
• IT services;
• Email service providers;
• Advertising partners;
• Payment processors.
We share all of the categories of personal information with these third parties when we
need to do so in order to provide you with Fountainhead products and services.
We may also share personal information with the following:
• Competent law enforcement bodies, regulators, government agencies, courts or
other third parties where we believe disclosure is necessary (i) as a matter of
applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or
(iii) to protect your vital interests or those of any other person;
• Actual or potential buyers (and their agents and advisers) in connection with any
actual or proposed purchase, merger or acquisition of any part of our business,
provided that we inform the buyer it must use your personal information only for the
purposes disclosed in this Privacy Policy;
• Other persons where you have given your consent.
5. Cookies and other tracking technologies
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use
personal information about you, including to serve interest-based advertising.
6. Children’s Privacy
In accordance with our Terms of Use, the Site is not designed for use by individuals under
the age of 18. Accordingly, we do not intend to or knowingly collect personal information
from anyone we know to be under 18 years of age. If you believe we have collected personal
data from anyone under 18, please contact us at the email address listed below.
7. Security
We have implemented various security policies, rules and technical and organizational
measures to protect and safeguard the personal information that we collect and process
about you. These measures are designed to provide a level of security appropriate to the
risk of processing your personal information.
8. California Privacy Information
If you are a California resident, the following information also applies to you and
supplements the information contained in this Privacy Policy.
Information We Collect and Sources of Information
In the past 12 months, we have collected the information described in the section
“Personal Information Fountainhead Collects” above, which also includes categories of
sources from which we have collected that personal information.
How we use and share information
We collect and use personal information for the business and commercial purposes as
described in the section “How Fountainhead Uses Personal Information?” above.
Fountainhead does not share your personal information except as approved by you or as
otherwise described in this Privacy Policy.
In the preceding 12 months, we have disclosed the following categories of personal
information described above for the business purposes described in this Privacy Policy:
• Identifiers such as those set forth above;
• Internet or other electronic network activity information;
• Demographic information / Protected Classification Characteristics;
• Commercial Information;
• Geo-location data;
• Audio, Video and other Electronic Data
• Professional or employment-related information; and
• Profiles and Inferences.
Under the California Consumer Privacy Act (CCPA), “sale” is defined very broadly and
includes a wide array of data sharing. As the term is defined by the CCPA, we “sold” the
following categories of personal information in the last 12 months: identifiers/contact
information, Internet or other electronic network activity information, and inferences drawn
from the above. We “sold” such information to advertising networks, data analytics
providers, and social networks. The business or commercial purposes of “selling” personal
information is for third-party companies to perform services on our behalf, such as
marketing, advertising, and audience measurement. We do not have any actual knowledge
that we “sell” personal information of consumers under 16 years of age.
Most modern web browsers give you the option to send a Do Not Track signal to the sites
you visit, indicating that you do not wish to be tracked. However, there is no accepted
standard for how a site should respond to this signal, and we do not take any action in
response to this signal.
California Privacy Rights
If you are a California resident, you have the following consumer privacy rights:
• Right to Know: You have the right to request that we disclose to you the personal
information we have collected, used, disclosed and sold over the past 12 months,
and information about our data practices.
• Right to request deletion: You can request that we delete personal information
about you. Although you may request deletion, we are allowed, under California
law, to keep certain personal information. You can submit a request to delete
by submitting a form here.
• Right to Opt-Out of “Sale” of personal information: You can opt out of the “sale” of
your personal information to “third parties” by clicking on this link (as those terms
are defined in the CCPA).
• Right to be Notified of Financial Incentives: You have the right to be notified of any
financial incentives oZers and their material terms, the right to opt-out of such
incentives at any time, and may not be included in such incentives without your
prior informed opt-in consent. We do not oZer any such incentives at this time.
• Right to Non-Discrimination: We will not discriminate against you for exercising any
of these rights.
California law also permits you to request certain information regarding the disclosure of
your personal information by us and our related companies to third parties for the third
parties’ direct marketing purposes. We do not disclose your personal information to third
parties for their own direct marketing purposes.
In addition to the specific forms listed above, you can exercise any of these rights by
contacting us at [email protected] and providing us with your name, email
address and address (including zip code) or by submitting a request to us through your
Fountainhead account. We may verify your identity by asking you to submit a request
through your password protected Fountainhead account and by providing us with your
California zip code or other proof of California residency.
You can also authorize an agent to submit a request on your behalf . An authorized agent
must have your signed permission to submit a request on your behalf or provide proof that
they have power of attorney in accordance with California probate law. Authorized agents
that are business entities must be registered with the California Secretary of State to
conduct business in California. Where you use an agent, we will ask for verification of your
authorization, namely a copy of your written authorization for the agent to submit the
request on your behalf.
We respond to all requests we receive from individuals wishing to exercise their data
protection rights in accordance with applicable data protection laws. We do not
discriminate against any consumer for exercising their consumer
rights.
Data Subject Rights
You have the following data protection rights:
• Right to access, correct, or request deletion: You may be able to do some of this in
your Fountainhead account or by contacting us.
• Right to object, or ask us to restrict processing: In certain circumstances, you can
request that we stop processing your personal information.
• Right to request portability: In certain circumstances, you can request that we
transfer personal information that you have provided to us in a structured,
commonly used, machine-readable format.
• Right to opt-out of marketing communications: You can exercise this right by
clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you
or by contacting us.
• Right to withdraw your consent: You can withdraw your consent at any time if you
previously gave us consent for processing of your personal information.
Withdrawing your consent will not aZect the lawfulness of any processing we
conducted prior to your withdrawal, nor will it aZect processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
• Right to complain: You have the right to complain to your local data protection
authority. For more information, please contact your local data protection
authority.
We respond to all requests we receive from individuals wishing to exercise their data
protection rights in accordance with applicable data protection laws. If you would like to
exercise any of these rights or would like further information please contact us using the
contact details provided under the “How to contact us” heading below.
Legal Basis
Our legal basis for collecting and using the personal information is usually as follows:
• Performance of a contract: where we need the personal information to perform a
contract with you, for example setting up and administering your account and
providing our products and services
• Legal obligation: where we have a legal obligation to collect personal information
from you, for example to comply with financial, accounting and other legal
obligations
• Legitimate interests: where the processing is in our legitimate interests and not
overridden by your rights, for example to analyse and improve how our products and
services are used, and to provide you with customer service
• Consent: where we have your consent to do so, for example in relation to certain
types of marketing
Data retention
We retain personal information we collect from you where we have an ongoing legitimate
business need to do so (for example, to provide you with a service you have requested or to
comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize it or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.
10. Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal,
technical or business developments. When we update our Privacy Policy, we will take
appropriate measures to inform you, consistent with the significance of the changes we
make.
You can see when this Privacy Policy was last updated by checking the “Last updated” date
displayed at the top of this Privacy Policy.
11. How to contact us
If you have any comments or questions regarding our Privacy Policy, or if you want to
exercise your rights, please contact us at [email protected]. We will address any
issue to the best of our abilities as soon as possible and respond to requests within the
time required under applicable law.