Effective Date: April 7, 2021
Last Updated: April 7, 2021
We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.
Personal information includes all information that relates to you or which are opinions about you personally and either identifies or may be used to identify you personally (collectively, "personal information"). We may collect the following types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services, such as:
Non-personal information includes information that does not personally identify an individual or information that has been anonymized (collectively, "non-personal information"). When we combine non-personal information with personal information, we treat the combined information as personal information.
You can always refuse to provide your personal information, except that it may prevent you from engaging in our Services or receiving responses to your inquiries or other information of interest.
We need to collect personal information from you in order to provide you with our Services, as well as to improve your experience. You may provide us with personal information in several ways, including, for example when you:
Visit our website or use our Services; Register for an account or membership; Correspond with us in any way, including through our virtual assistant, surveys, and promotions; Sign up to receive our newsletter or promotional information; Ask for customer service, support or other assistance; Interact with us in any other way, online or offline, including through our Services; Link an external brokerage or other financial institution’s account via Plaid (https://plaid.com/).
Like many websites and apps, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use the website. We use this information for analytics purposes which allows us to improve your browsing experience. The information we collect through these technologies will also be used to manage your session.
You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies, if you opt-out from cookies, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently support Do Not Track or similar signals, which means that we may collect information about your activity both while you are using the Services and after you leave our website.
We also may collect personal information from other sources, such as our partners or third party service providers, or from our offline interactions with you for the purposes listed in the How We Use Personal Information section below, including to enable us to verify or update information contained in our records and to better customize the Services for you.
Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, including the information listed in the Types of Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.
We may use personal information to do any or all of the following:
We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.
We may retain personal information for as long as we need to use the information for the purposes listed above, including, for backup, archival, accounting, and/or audit purposes.
We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.
Except as disclosed in this Privacy Notice, we do not share personal information with any companies other than our partners and affiliates and their directors, officers, employees, agents, consultants, advisors or other representatives.
We may share personal information with our third party service providers, suppliers, vendors, and business partners to help us:
We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
We may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.
We share non-personal information with third parties as reasonably necessary to meet our business needs.
We are dedicated to ensuring the security of your personal information. We aim to provide secure transmission of your personal information from your devices to our servers. We have processes to store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.
Our Services are not for children or those under the age of 13. We do not knowingly collect personal information from children or other persons who are under 13 years of age. Individuals who are children or those under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 13, please contact us immediately.
We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To make any request pursuant to California privacy law, please contact us.
We offer you certain choices in connection with our Services.
Updating your personal information
The accuracy of the personal information we have about you is very important. To submit a request to update or correct your information, please contact us using the information below.
Email Communications / Direct Marketing
You may have the opportunity to receive certain email communications from us related to our Services. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these necessary emails, if lawful and appropriate, even if you unsubscribe from our optional marketing communications.
Cookies / Beacons
If you wish to minimize information collected by cookies or beacons, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
Network Advertising Initiative
Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt-out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Please note that even if you choose to remove your personal information (opt-out) you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt-out of certain online behavioral advertising, please visit http://www.aboutads.info.
Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
Do Not Track
Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit.
Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.
Our website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.
We welcome questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have questions, concerns, or feedback, you can always contact us using the methods below. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.