Privacy Policy

We understand that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We want you to know what information we collect, and how we use and safeguard that information.

Information We Collect

We collect certain non-public information about you ("Customer Information"). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

How We Use the Information We Collect

We use the Customer Information we collect from you and third parties to operate our services, communicate with you, conduct research and development to improve or enhance our services and our users' experience, and promote our services. Here are a few examples of what we do with the information:

Security of Your Information

We restrict access to your non-public personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your non-public personal information.

Information We Disclose

We do not disclose the non-public personal information we collect about our customers to anyone except: (i) to persons necessary to effect transactions and provide the authorized services (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, consultants, etc.); (iii) agents acting on our behalf (e.g. service providers or agents in order to have them perform on our behalf); (iv) our attorneys, accountants, and auditors; or (v) as otherwise provided by law.

We have retained the services of a third-party account aggregation service provider ("Aggregator") to provide us information about client accounts that have been linked through our platform. Aggregator collects Customer Information from third party data sources in connection with the operation of our advisory services. If you link accounts through our platform by inputting your login credentials, Aggregator can (a) use your account information, account access information, and registration information internally to provide and improve Aggregator's services (but not directly for the benefit of any third party); (b) to the extent permitted by law, use, sell, license, distribute and disclose Customer Information and usage information that has been stripped of all personally identifiable information ("Anonymized Data"); and (c) to perform fraud screening, verify identities, and verify the information contained in your accounts for use across the Aggregator network. Aggregator will not disclose your Customer Information to any third-party other than as Anonymized Data, or use your Customer Information to directly solicit you or other customers.

We are permitted by law to disclose the non-public personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose. We only provide these third parties with the minimum information they need to perform their specific function and they are prohibited from using or sharing the information for any other purpose. We also require these third parties to safeguard your information.

Advertising Service Providers

Some of our third-party service providers or partners are advertising networks, marketing partners, publishers and other entities who perform analytics and advertise our products and services on websites not affiliated with us ("Advertising Service Providers"). In connection with these advertising services, we or our Advertising Service Providers, like Google Analytics (more on this below) may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other websites in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you ("Interest-Based Advertisements"). Our Advertising Service Providers may permit you to opt out of all or some Interest-Based Advertisements on designated websites. For example, many of our Advertising Service Providers participate in the Network Advertising Initiative opt-out program or the Digital Advertising Alliance opt-out program.

Disclosure Regarding Google Analytics Advertising Features

In addition to services from other Advertising Service Providers, we use the following Google Analytics Advertising Features as part of our marketing analytics and advertising: Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time. At present, Google provides users an opportunity to opt-out of the Google Analytics Features through Google's Ads Settings and their web browser opt-out plugin. However, we do not control these opt outs, which may be updated or removed by Google in accordance with its own policies. For additional information on opting out of interest-based ads by Google, you can visit Google's Opt out page here.

Cookies, Analytics and Traffic Data

Cookies are small text files which are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalized service, and to help make our websites, applications and services better for you.

Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to "remember" who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).

We use the following different types of cookies:

Former Clients

If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

Changes to Our Privacy Policy

In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.