Policy Effective Date: Effective January 1, 2020
FinanceCreation’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.
The categories of information we collect depend on whether you are a current or former User, and/or Client. Examples of instances when we collect Personal Information include:
We collect Personal Information from Users, including but not limited to your:
If you choose to become a Client, in addition to the information we collect from you as a User, described above, we will ask you for certain additional Personal Information, including but not limited to:
Many of FinanceCreation’s Users and Clients choose to aggregate information from accounts at other financial institutions onto their dashboard on our Site or in our App; in enabling this functionality, FinanceCreation acts as an agent to retrieve the User or Client account information maintained by such third-party financial institutions with which the User or Client has a legally-binding customer relationship (“Account Information”). This Account Information may include account balances, transactions and holdings from the linked financial institutions.
By choosing to use our Services to aggregate and analyze your Account Information, you expressly authorize and direct FinanceCreation, on your behalf, to electronically retrieve all Account Information associated with the username and password that you use to link the account. FinanceCreation does not store login credentials used to link Account Information. Rather, FinanceCreation works with one or more third-party service providers to access and retrieve your Account Information. Any Account Information that FinanceCreation receives is read-only and cannot be altered by FinanceCreation or the third-party service provider we use to access and retrieve your Account Information. Any Account Information transmitted from a third-party financial service provider is transmitted via end-to-end encryption, and any credentials you provide are encrypted at rest.
FinanceCreation manages a referral program called “The FinanceCreation Invite Program.” The program allows our Clients to lower their annual advisory fee in exchange for referring a person who becomes a client. Participation in our referral program is free and voluntary for our Clients. By participating, you are asked to provide us with the name and e-mail address of the person to whom you refer our Service. We treat this information like all our other Personal Information.
Due to the nature of our business, our Services are not made available to minors. Except for beneficiary information as described above, FinanceCreation does not knowingly solicit Personal Information from or about children under the age of 18.
If you are under the age of 18, please do not submit any Personal Information to FinanceCreation.
If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files.
If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at [email protected] and we will delete such information from our files.
Other means by which we collect Personal Information include the following:
We will never rent, sell or trade your Personal Information to anyone. Ever.
We use your Personal Information for a variety of business purposes, such as to help you evaluate our Services, offer you new products or services, enhance our Services, and for research and internal analysis.
FinanceCreation stores, processes, and maintains Personal Information related to you for a variety of business reasons such as to provide client support, analyze and improve our Services, offer new products or services and provide our Services to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client.
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your computer. To do this, we may analyze your browsing patterns, geo-location and device identifiers to match the information of the browser and devices that appear to be used by the same person.
We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other FinanceCreation promotional or marketing purposes. In some jurisdictions, we are required to publicly share some winner information.
We will not share or disclose your Personal Information (whether you are a current or former User and/or Client) to any nonaffiliated third-parties except:
To Protect Ourselves or Others. We may share your Personal Information as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the personal safety of any person, if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our or others’ rights, property, or safety; enforce our policies or contracts; or collect amounts owed to us.
Affiliates. FinanceCreation may share your Personal Information among affiliated FinanceCreation entities in connection with the provision of Services to Clients and Users.
Service Providers. There are certain circumstances in which we may share your Personal Information with non-affiliated third-party service providers, including to perform certain business and technology related functions and to support the provision of the Services. We may share your Personal Information with non-affiliated third-party service providers for the provision of services, which includes but is not limited to the following: mailing information; trade settlement and clearing; data processing and storage; payment processing; identification verification and fraud detection; customer support; and marketing.
Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services. For example, we may share the information required to become a Client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide and facilitate the provision of Services to you.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract.
You may decline to provide Personal Information to FinanceCreation. Declining to provide Personal Information may disqualify you from using FinanceCreation Services, Site, and App features that require certain Personal Information.
Where you have consented to FinanceCreation’s use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us by email, phone or physical mail via the contacts indicated under the “Questions and Contacting Us” section below. Additionally, before we use Personal Information for any new purpose we will provide information regarding the new purpose. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
Users or Clients may contact us at [email protected] to request information about how to access your Personal Information.
You may request deletion of Personal Information by contacting us at [email protected] and providing us enough information to identify your account and prove that you are the owner of the identified account. However, due to regulatory recordkeeping obligations we may retain information related to you and your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies, to support processing of settlement of your transactions, or in accordance with applicable laws.
FinanceCreation takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free; therefore, we cannot ensure or warrant the security of any information you transmit to us.
California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. FinanceCreation does not share Personal Information with third-parties for their own marketing purposes.
The California Consumer Privacy Act permits certain Users (users of our financial planning services who have shown no indication of becoming a Client) who are California residents to request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request. The California Consumer Privacy Act also gives Users the right to request permanent deletion of Personal Information, which Users can do by following the procedure above.
FinanceCreation does not sell your data. FinanceCreation only discloses Personal Information to unaffiliated Third Parties as set forth in this Policy. You have the right to request information from us regarding whether we share certain categories of your Personal Information with third parties for FinanceCreation’s marketing purposes. To the extent we share your Personal Information in this way, you may request information related to (i) the categories of information we disclosed to third parties for such purpose during the 12 months and (ii) the names and addresses of third parties that received such information.
Questions and Contacting Us