Wealth PFM LLC (“Wealth”) Privacy Policy. This Privacy Policy was published January 15, 2021.
Introduction and overview
This Privacy Policy forms part of the Wealth Terms of Service available at https://wealth.financial/app. This Privacy Policy also applies to visitors of the Wealth website and the users of the Wealth mobile app. You agree to the terms in this Privacy Policy when you sign in, activate or use the Wealth Services.
Scope of this Privacy Policy
Wealth provides online services for managing a portfolio of financial services for professional financial managers (the “Wealth Services”). This Privacy Policy (“Privacy Policy”) describes our privacy practices for individuals in the United States when we process Personal Information for the purposes of providing the benefits of the Wealth Services, including through our mobile applications and desktop applications. “Personal information” means data that identifies and is associated with a specific person. Personal information does not include information that is anonymous and aggregated or is no longer identifiable to a specific person.
This Privacy Policy does not apply where Wealth processes Personal Information as a service provider on behalf of a customer or entity who alone or jointly with others determines the purposes and means of the processing of Personal Information (“Information Controller”), for example, professional financial managers. When we act as a service provider, the Privacy Policy of the relevant Information Controller and our agreements with such business or entity will govern our processing of Personal Information.
Wealth Account information
The Personal Information you provide is the combination of information that Wealth has about you (“Wealth Account”). Your Wealth Account includes your credentials; your name and contact details; payment information; any information about your activities, interests or preferences you enter; the content you place in our platform; and any information we have collected about you from third-party sources and insights that are associated with you.
Information we collect
Information you give us
The Personal Information that we receive about you depends on the context of your interactions with Wealth, how you configure your Wealth Account and the choices that you make, including your privacy settings. Personal information that you provide may also depend upon what services or experiences you use, your location and applicable law.
- Creating an account. We collect information when you create an account, interact with Wealth Services or activate a subscription. Personal information may include your contact information (such as your name, address, phone number and email), profile photo, billing information (your payment information), usernames and credentials.
- Identification information. We may collect information to verify your identity, including your name, social security number, social insurance number, driver’s license numbers, government-issued identification details, for example to verify your identity.
- Customer support, product research, training and feedback. We may collect Personal Information when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share.
- Information about others: Please see the section titled, “Information provided by others”, below.
Information we get when you use the products and services.
We may collect certain information about you when you access or use the Wealth Services. This may include:
- Device information. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
- Content. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information.
- Third-party service content. We receive information about you when you sign into a third-party service with your Wealth Account or when you connect your Wealth Account to a third-party service. For example, you may choose to connect your Wealth Account with bank accounts in order to download and sync financial information.
- Usage information. We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you interact.
- Information from cookies and other technologies. Wealth may use common tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively "cookies") to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers' experience. The Wealth Services is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted. You have control over some of the information we collect from Cookies and how we use it.
- Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. We may also store Personal Information locally on your device.
Information provided by others
You may be able to input or process information about others, for example, if you are an account administrator. If you input information about others into our platform, you must only do so if you have first received the appropriate rights and permissions to do so, including by getting advanced written consent, if required by applicable law.
At Wealth, we believe that you have rights to information that pertains to you, your household and/or your business. If another person has input or processed information in the Wealth Services on behalf of you, your family or your business (and we are processing such information as an Information Controller), you may ask to receive a copy of your information, even if you do not have an account with us. To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to receiving a copy of the information. For specific instructions on how to request a copy of your information, please see the section “Your information rights and choices” below.
We also obtain information from outside parties or services to run our business. We protect and process information obtained from those parties as described in this Privacy Policy, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the Wealth Services. For a list of the categories of sources from whom we obtain information, please see the section “Other information sources” below).
Other information sources
We may also get information about you from others where permitted by applicable law. For example, we receive information from:
- Your service providers. If you choose to sync a non-Wealth account/service with your Wealth Account, we will receive information from that account/service according to your settings with that account/service.
- Support providers. Service providers who provide us with information about you or your interaction with the Wealth Services. For example, we may obtain service and support information or technical issues you have raised with these third parties.
- Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your Personal Information.
- Publicly-available Sources. We may collect information from publicly available sources, such as open government databases.
How we use Personal Information
We collect and process Personal Information from you only where:
- We have your consent to do so
- We need the Personal Information to perform a contract with you or provide a service to you
- Provide you with the benefits of the Wealth Services and operate our business
- To comply with legal requirements, including applicable laws and regulations
Personal information is used to operate our business, including but not limited to:
- Provide you with the Wealth Services and create your Wealth Account
- Improve our products and services
- Run and manage our business, including resolving billing and financial disputes
- Communicate with you
- Personalize your experience
- Provide you with support and resolve disputes
- Conduct research, including by partnering with academic institutions
- Comply with our legal and regulatory requirements
- Protect the rights, property, safety or security of Wealth, the Wealth Services, our customers, employees or others and prevent fraudulent or illegal activity
- To enforce, remedy or apply our Terms of Service or other agreements.
How we share your information
Sharing your Information
With your consent. We share your information with third parties when you have requested us to do so.
For research. With appropriate controls, we may share information with third parties for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.
With service providers. We share Personal Information with our service providers who provide services on our behalf for the purposes described in this Privacy Policy. Service providers are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Policy.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company (collectively, a “Transaction”), we may share your information with that company and its advisors before and after the Transaction date.
Sales of Personal Information to third parties. We do not and will not sell Personal Information to third parties. We do share Personal Information with third parties for the business purposes described in this Privacy Policy.
Non-Wealth Services, links and integrations
Other companies’ products, services and applications may use or integrate with our Wealth Services, or otherwise be offered through our Wealth Services (“Non-Wealth Services”). If you choose to link, sync or otherwise use any of these Non-Wealth Services you consent and direct Wealth to share your information, including Personal Information, to the company providing the Non-Wealth Services. Non-Wealth Services are subject to the applicable terms and Privacy Policy of the company providing the service.
Sharing Personal Information for legal reasons
We may share your information with third parties for legal reasons, including:
- When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process
- To protect the rights, property, or safety of Wealth, our customers or others
- To protect or defend against attacks
- To enforce, remedy, or apply our Terms of Service or other agreements
- To prevent fraud, cybersecurity attacks or illegal activity
- For debt collection.
Your information rights and choices
You have rights and choices when it comes to managing the privacy of your Personal Information.
Update your privacy settings. You may update your privacy settings by visiting your Wealth Account settings.
Manage marketing communications from us. To update your marketing communication preferences, you can go to the marketing preference tools in your Wealth Account settings. You may also click unsubscribe at the bottom of the marketing emails or respond with STOP to SMS messages.
Download a copy of your Personal Information. You may request a copy of your Personal Information by visiting your Wealth Account or our Privacy Center.
Correct your Personal Information. You can edit and correct your Personal Information at any time by changing it directly in our products and services.
Delete your Personal Information. Subject to certain limitations, you may request for us to delete your Personal Information by visiting your Wealth Account settings.
Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings or make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.
Depending on where you live, you may have other certain state-specific legal rights with respect to your Personal Information that we collect and process. In addition to accessing your Wealth Account settings for information, you can file a request or take action by contacting us at the contact details provided under the section “How to contact us.” Wealth does not discriminate against users for exercising any privacy rights.
Information retention
Unless you specifically ask us to delete your Personal Information as explained in section “Your information rights and choices,” above, we retain your Personal Information as long as it is necessary to comply with our data retention policies and obligations. For example, we may maintain your Wealth Account for our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us), to exercise, establish or defend legal claims and to protect against fraudulent or abusive activity on our service.
There may be occasions where we are unable to fully delete or de-identify your information due to technical or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your Personal Information from any further processing until such time as we are able to delete or de-identify it.
Security of your Personal Information
Wealth takes the security seriously. We use technical and administrative security measures such as, but not limited to, firewalls, encryption techniques, and authentication procedures, to maintain the security of your online sessions. We use physical, technical, and organizational safeguards designed to protect your information. However, despite these controls, we cannot completely ensure or warrant the security of your information.
How to contact us
If you have questions or comments about this Privacy Policy or our practices, please contact us by sending an email to info@wealth.financial.
Changes to our Privacy Policy
From time to time we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your Personal Information, we will notify you by posting a notice in our platform or on a community post, by sending you a notification or by other means consistent with applicable law.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy. Please review this Privacy Policy periodically to stay informed about how Wealth protects your privacy.
Collection and use of children’s Personal Information
Our services are not intended for or directed to anyone under the age of 16 We do not knowingly collect Personal Information from users under the age of 16. If you believe we may have information from a anyone under the age of 16, please contact us.
