Last Revised: July 12, 2021
Personal Information We Collect
When you interact with the App, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you use the App, we may collect information about the individual web pages that you view, what websites or search terms referred you to the App, and information about how you interact with the App. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the App, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the App.
Additionally, we may collect certain personal information that you provide to us via the App from time to time, such as your name, telephone number and email address.
You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the App. You may not send us any sensitive personal information (e.g., social security number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise.
How Do We Use Your Personal Information?
We and our service providers use personal information for our legitimate business purposes, including those specifically described below. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or because we have a legitimate business interest.
We use the personal information that we collect generally to fulfill any requests made through the App. Additionally, we use personal information to communicate with you, personalize your experience on the App, and, when in line with the preferences you have shared with us, provide you with information or advertising relating to Company and/or RIAs, which may include their products or services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize the App (for example, by generating analytics about how our users browse and interact with the App.
Sharing Your Personal Information
Do Not Track
Jurisdiction and Cross-Border Transfer
Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Options Regarding Your Personal Information
If you would like to delete, update, or access the personal information we have collected from you, you can send an email to us at email@example.com. We will delete your personal information from our active databases following your verified request, however, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms of service, and/or comply with legal requirements.
Emails and Other Communications
If you no longer wish to receive communications (including, without limitation, email and SMS/MMS messages) from us, you may opt-out by emailing us at firstname.lastname@example.org. If you no longer wish to receive communications (including, without limitation, email and SMS/MMS messages) from a third party (including the RIA(s)), you are responsible for contacting the third party directly.
We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you, when we have a legal obligation to which we are subject, or as advisable in light of legal requirements.
Security of Your Personal Information
We use administrative, technical and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information to us.
The App is not intended for individuals under 18 years of age. We do not knowingly solicit information from or market to individuals under 18 years of age. If you become aware of any data we have collected from individuals under 18 years of age, please contact us using the contact information provided below.
Under the California Consumer Privacy Act of 2018 (“CCPA”), Company is a “service provider” of the applicable RIA(s), which may be a “business” covered by the CCPA. As a “service provider”, Company processes your personal information in order to provide its services to the RIA(s), and in order to facilitate your interactions with the RIA(s). To learn more about rights that you may have under the CCPA, such as the right to request information about the types of your personal information that has been collected, the right to request that your personal information be deleted, and the right to opt-out of the sale of your personal information, please contact the applicable RIA(s).
Company and the App comply with the CCPA and other applicable laws. If you’d like to make a request to Company regarding your personal information, please contact us by e-mail at email@example.com, and we will reasonably try to accommodate your request unless we are prevented from doing so as a result of applicable law or a significant legitimate interest of Company. Please also note that, depending on the nature of your request, the fulfillment of your request may hinder or prevent Company’s ability to provide you with certain features and functionalities of the App.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org or by mail using the details provided below:
272 Ruth Road
Harleysville PA 19438
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