Portfolio Approach To Risk Management
Portfolio Approach Definition
Portfolio Appeal Process
Portfolio Approach Asc 842

Use of Personal Information

Security Questions Important Note: Answers to selected questions will be required in order to reset your password. Virtual Portfolio Manager allows to create several Portfolios and add your financial Instruments as Positions to each of them. You are able to manage several Portfolio and to see the Profit and Losses of each of them. The app queries the current price of the added Instrument and allows to manage several Currencies.

We do not collect any personal information unless you voluntarily provide it by sending us email, participating in a survey, or completing an online form. Personal information submitted will not be transferred to any non‐affiliated third parties unless otherwise stated at the time of collection. When a user submits personally identifiable information it is used only for the purpose stated at the time of collection.

Privacy and Personally Identifiable Information. Cadet Portfolio anticipates that it will follow the precedent of JROTC Unit Management System ('JUMS') for cadet data collection of Personally Identifiable Information ('PII'). It is expected that all data will be generated by the cadet. All PII will be maintained in compliance with applicable state and federal laws and regulations governing same, including without limitation, to the extent applicable (i) the Department of Defense Privacy Program (32 CFR, Subtitle A, Chapter I, Subchapter O, Part 310); and (ii) The Privacy Act of 1974 (5 U.S.C., subsection 552a). Cadet Portfolio will perform periodic assessments to ensure that PII is maintained in compliance with existing and future updates to privacy laws.

Consent

Where consent for the use and disclosure of personal information is required, the company will release the information pursuant to applicable law.

Registration

In order to use this website, a user must first complete the registration form. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on our site in which you have expressed interest. We do require verification at registration for age due to age restrictions for our website.

Log Files

Like most standard website servers we use website statistic packages such as Google Analytics to analyze trends in how our website is accessed and utilized. Information monitored includes Internet protocol (IP) addresses, geographic location of visitors (country, city), browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, time spent on pages, and keywords used to find our site via search engines. This information is anonymous and cannot be directly linked to individual users. We may use it to identify high‐use or low‐use areas of the site, pinpoint problem areas of the site, analyze broad demographic trends in our visitors, and make decisions about how to make it easier for people to find and navigate our website.

Google Analytics

This website uses Google Analytics to help understand how visitors engage with the site. Your web browser automatically sends certain information to Google. This information is anonymous and cannot be directly linked to individual users. This includes, for example, the web address of the page that you are visiting and your IP address. Google may also set cookies on your browser, or read cookies that are already there. If you would like further information on how Google uses data when you use our website, you may visit http://google.com/policies/privacy/partners.

Links

This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

Security

This website takes every precaution to protect our users' personal information. Whenever users submit personal information, registration, or online purchase, upon submission that information is encrypted via the highest level of SSL (Secured Sockets Layer) available. Servers that store personally identifiable information are in a secure environment.

Cadet Portfolio will utilize Amazon Web Services ('AWS') for Cloud Hosting (https://aws.amazon.com/security). AWS is currently used by many different federal governmental agencies and subdivisions, including the Department of Defense, the National Security Agency and the Central Intelligence Agency. Through AWS, Cadet Portfolio will maintain data security under the AWS shared responsibility model to ensure full compliance with The Family Education Rights and Privacy Action of 1974, as amended ('FERPA') (https://goo.gl/WE6PhF). Cadet Portfolio, through AWS, offers a host of features to ensure full FERPA compliance, which features can include cross-service security controls, service-specific security controls, optimized networks, and operating system and applications controls. Cadet Portfolio's use of AWS allows for fully customizable services to allow the creation of a FERPA-compliant environment, including use of such tools as necessary or required by FERPA, which may include built-in firewalls, authentication and authorization, private subnets, encrypted data storage, dedicated connection options, perfect forward secrecy, security logs, and other cutting-edge and FERPA-compliant data security services and features. In addition to FERPA compliance, Cadet Portfolio will maintain and secure data in compliance with all applicable federal and Department of Defense contracting requirements, including without limitation, to the extent applicable (i) Defense Federal Acquisition Regulation Supplement ('DFARS') Parts 202, 204, 212, 239 and 252, with specific reference to DFARS regulations 252.204-7010 and 252.204-7012; (ii) security controls based upon National Institute of Standards and Technology ('NIST') Special Publication 800-171; (iii) Federal Risk and Authorization Program ('FedRAMP') processes, including compliance with the Cloud First Policy as applicable; (iv) the Department of Defense Security Requirement Guide; and (v) the Federal Information Security Management Act of 2002 (44 U.S.C. § 3541, et seq.). Additionally, to the extent necessary to comply with existing or future data security requirements, Cadet Portfolio will implement use of AWS' GovCloud commercial cloud services, in whole or part, as may be applicable or necessary. Under no circumstances are credit card numbers permanently stored on our website servers.

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact us at info@cadetportfolio.com or 1-866-GO-JROTC (1-866-46-57682).

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