Privacy Policy

Last updated: September 2024

Welcome to Mount Ararat Financial Services LLC (“Mount Ararat Fin Svc”). This Privacy Policy outlines how Mount Ararat Fin Svc and https://MountAraratFinancialServices.com/ (the “Website”) (collectively, “we”, “us,” or “our”) collects, uses, protects, and discloses information about you when you use our services, including, for example, when you use our Website, our online services, subscribe to receive communications from us, or otherwise interact with us.

Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are more stringent than those required by federal law. Federal law gives the client the right to limit some, but not all, sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

Please read this Privacy Policy carefully and contact Mount Ararat Fin Svc if you have any questions. Our contact details can be found on the Contact Page of our Website, and in Section 11 (below).

If you have provided us with your information, then this indicates that you have had sufficient opportunity to access this Privacy Policy and that you have read, understood, and accepted this Privacy Policy.

If you do not wish to provide personal information to us, then you do not have to do so, however, this may adversely affect your use of our Website and any services offered by us to you. Moreover, if you decide not to provide us with certain information that is necessary for us to perform our services, we may exercise our right to terminate our engagement with you.

Please continue reading to understand what information Mount Ararat Fin Svc collects and how we use it.

1.    Collection of Personal Information, Non-identifiable Information, and Aggregated Data

Personal Information: The types of Personal Information we collect, share, and use depend on how you have interacted with us and the purpose(s) for which we are collecting it. For example, we may ask for:

●       First and last name;

●       Contact details, including e-mail address, address, and telephone number;

●       Date of birth;

●       Demographic information such as state and/or postal code;

●       Your preferences in receiving marketing and communications from us;

●    (If contracting to receive our services) Information such as your income, expenses, net worth, risk tolerance, and investment objectives;

●       Credit card information;

●     Your investments, including the names of investment funds and the ticker symbols of the funds (the identifier under which a security trades on an exchange) in which you have invested; and

●       Any other information requested on this Website or otherwise requested by us or provided by you.

Sensitive Personal Information: In our efforts to provide the most comprehensive and tailored services to you and help you plan for life events, we may ask clients of our Comprehensive Financial Plan Development Service and Ongoing Financial Planning Service for special categories of Personal Information, also known as “Sensitive Personal Information.” This information may include, among other things, your race/ethnicity, sex, marital status, whether you are a member of a labor union or an employee association that is similar to a labor union, and certain health information, such as information related to family planning (e.g., plans for having children).

We limit our use of your Sensitive Personal Information to that which is necessary to perform our services. We only use or disclose Sensitive Personal Information for legitimate business purposes, consistent with current privacy regulations, provided that such use or disclosure is reasonably necessary and proportionate for this purpose. 

We do not sell or commercialize your Sensitive Personal Information to third parties for marketing or promotional purposes.

Non-identifiable Information: This means data that has never been labeled with individual identifiers or from which identifiers have been permanently removed, and by means of which no specific individual can be identified. When you visit our Website, we automatically record Non-identifiable Information about you that your browser sends. This data may include:

●       Your computer’s IP address and geolocation data;

●       Browser type;

●       Operating system;

●       Access times;

●       Webpage you were visiting before you came to our Website;

●       The pages within https://MountAraratFinancialServices.com/ you visit; and

●    The time spent on those pages, items and information searched on our website, access times, dates, and other statistics.

Non-identifiable Information is collected for analysis and evaluation in order to help us improve our Website and the services we provide. This data will not be used in association with any other Personal Information.

Aggregated Data: We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data will not directly or indirectly reveal your identity. If, however, we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we will use the combined data outcome in accordance with this Privacy Policy.

Data Relating to Minors: Our Website is not intended for children and/or minors under the age of 16, and we do not knowingly collect data relating to children and/or minors on our Website. If you are a client of our Comprehensive Financial Plan Development Service and/or Ongoing Financial Advice Service, we may ask you for Personal Information related to minors (e.g., date of birth, state of residence, information about scholastic performance, plans for college, health, and potential learning disabilities and cognitive disorders), if and to the extent you request our advice related to education planning or other financial planning for minors in your household. If this is the case, we will ask you, as the parent or guardian, for your consent prior to knowingly collecting the minimum amount of Personal Information about the minor or minors that we need to provide you with our services.

2. How We Collect Your Data

We may collect your information in several ways, including directly from you, when you:

●       Browse our Website;

●       Contact us or give us feedback;

●       Interact with Dr. David Nanigian’s personal social media accounts;

●       Interact with us directly, in person;

●       E-mail us or otherwise interact with us online;

●       Request that marketing material be sent to you;

●       Speak with us by telephone or leave a voicemail message;

●       Use our services, including by accessing them online/remotely.

Kindly note that if you fail to provide Personal Information when requested in circumstances in which we need to collect personal data by law, or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). We will notify you if this is the case using the contact information you have provided to us.

3. How We Use and Process Your Personal Information

We will only use your Personal Information when the law allows us to and in order to provide the best possible services to you. Most commonly, we will use your Personal Information in the following circumstances:

●       To respond to communications from you;

●       To create and process transaction-related information, such as invoices, and agreements for our services;

●       To communicate with you about our services and to perform those services;

●       To perform research and analysis;

●       To relay out-of-office notices due to personal or medical emergency;

●       For market research and business development, including development of the Website;

●       To deliver personalized content to you;

●       For marketing purposes, including direct marketing;

●       To send you information about financial products and services offered by third parties that we think may be of interest to you. These may include self-clearing brokerages with software for account opening (e.g., Altruist and Schwab), budgeting apps/services, estate planning apps/services, information about specific investment funds, insurance products, and bank or credit union accounts;

●       To provide customer support;

●       To notify you about changes to our services;

●       To monitor the usage of our Website and other internal metrics;

●       To detect, prevent, and address technical issues; and

●      To comply with laws and regulations or to comply with any directions given by regulators or other authorities, such as professional certification organizations.

4. Disclosure of Personal Information to Third Parties

We may disclose your Personal Information, including your Sensitive Personal Information, to third parties to:

●       Conduct market research and marketing strategy analysis;

●       Assist us in providing products and services you have requested, such as AdvicePay, which is the payment processor we use;

●       Open an account with a custodian, if you have entered into an Investment Account Agreement with us and directed us to do so;

●       Service providers based in the United States that provide IT or other system administration services;

●    Professional advisors, including attorneys, bankers, auditors, and insurers, based in the United States, that provide consultancy, legal, banking, accounting, and/or insurance services;

●       Credit card issuers, if you dispute a charge from us on your credit card billing statement;

●    Courts, tribunals, regulatory authorities, professional certification organizations, including Certified Financial Planner Board of Standards, Inc. (“CFP Board”), and law enforcement offices as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights, or demonstrate our compliance with our legal obligations relating to, for example, Know Your Consumer (“KYC”) and anti-money laundering, or to demonstrate compliance with an investigation by CFP Board for a potential violation of CFP Board’s Code of Ethics and Standards of Conduct.

Where we disclose your Personal Information to third parties for these purposes, we will request that they follow this Privacy Policy when using your Personal Information.

5. Gramm-Leach-Bliley Act and Your Right to Limit Sharing of NPI

As an investment advisory firm, we are subject to the Gramm-Leach-Bliley Act (“GLBA”), a federal law. The GLBA requires that you are given notice and the opportunity to opt-out of sharing with nonaffiliated third parties for marketing purposes bank account and financial data, personal income information, Social Security data, tax information, and other personally identifiable financial information that you share with us, or that we otherwise obtain in providing financial services to you that is not accessible or available in public records (known as “NPI”). A nonaffiliated third party is a company that is not related to us by common ownership or control.

NPI may be shared without your permission in certain circumstances. For example, NPI may be shared with a third party if it is provided to that third party to perform services for Mount Ararat Fin Svc. In those circumstances, we will inform you about the information-sharing arrangement and ensure that there is a confidentiality agreement protecting the information between us and that nonaffiliated third party.

Please refer to the table below for more information on what we share and your rights to limit this sharing (“opt-out”), but keep in mind that we do not currently share your information to nonaffiliated third parties for marketing purposes.

*Affiliates are financial and nonfinancial companies that may be related by common ownership or control. Mount Ararat Fin Svc currently does not have any affiliates.

The GLBA gives you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliated third parties who use your information to market to you. Again, we currently do not engage in sharing your information for those prescribed purposes.

6. Change of Control of Our Business or Sale of Business Assets

We do not sell or commercialize your Personal Information to third parties.

We may share information with:

●       Service providers performing services on our behalf (see Section 4 above);

●       Law enforcement or government agencies as required by law;

●       Business transferees in connection with a sale, merger, reorganization or liquidiation.*

*If there is a change of control of our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permitted by law, our user databases, together with any Personal Information, including Sensitive Personal Information, and Non-identifiable Information contained in those databases. This information also may be disclosed to a potential purchaser. If you wish that we delete such information in the event of a change of control of our business or sale of our business assets, please contact us.

7. Security of data

We take reasonable measures to protect your Personal Information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to, computer safeguards and secure digital files. No internet transmission, however, is entirely secure, and we cannot guarantee the security of your data transmitted to our Website.

8. Third-party websites

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or the content of such websites.

9. Do Not Track Signals

We do not currently respond to 'Do Not Track' signals, as there are no universal ‘Do Not Track’ standards, implementations, or comprehensive solutions at present.

10. How to Access or Rectify Your Personal Information

You may ask us, in writing, to provide you with details of the Personal Information we currently hold about you. We will endeavor to process your request as soon as possible.

You can:

●       Review the Personal Information we have about you or request a copy of it;

●       Ask us to update or rectify Personal Information if it is inaccurate;

●       Request that we delete your Personal Information;

●     Opt-out of sharing your Personal Information with third parties for a particular purpose, including sharing that may be defined as a sale under applicable state laws;

●       Object to certain types of uses of your Personal Information; and

●       Make choices about receiving e-mail marketing.

11. Controller and Contact Details

Mount Ararat Fin Svc is the controller and is responsible for your Personal Information. If you have any questions about this Privacy Policy, our privacy practices, or would like to correct or delete your information, please contact us directly in the following ways:

By mail to:

Mount Ararat Financial Services LLC

1220 L ST NW

STE 100205     

Washington, DC 20005

By e-mail to: info@MountAraratFinancialServices.com

12. Privacy Policies of Other Websites

Our Website may contain links to other websites. Be advised that our Privacy Policy only applies to our Website. If you click on a link to another website, you should read their privacy policy to understand how your data will be used from your interactions with that website.

13. Changes to the Privacy Policy and Your Duty to Inform Us

This Privacy Policy may be amended, including with changes, additions, and deletions, from time to time, in our sole discretion and as prescribed by updates in state and federal law. We will notify you by e-mail of changes to the Privacy Policy. Your continued use of our Website or services following any amendments indicates that you accept the amendments. We recommend that you check this Privacy Policy regularly, prior to providing Personal Information, to ensure that you are aware of any changes, and only proceed to provide Personal Information if you voluntarily accept our updated Privacy Policy.

In order to provide you with the best service and safeguards, it is important that the Personal Information we hold about you is accurate and current. In particular, please ensure that your contact information is accurate and current, because that is how we will reach out to you in the event of changes. Please keep us informed if your Personal Information, including your contact information, changes during your relationship with us.