Policy Effective Date: Effective January 1, 2021
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.
We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”) and to assist you in exercising your privacy rights.
FinanceCreation Corporation and/or its affiliates (“FinanceCreation”, “we”, “us” and/or “our”) currently offer a cash product, financial planning software and portfolio management services, and may offer additional products and services in the future (collectively, the “Services”), through FinanceCreation’s website, www.wealthfront.com (“Site”) and our mobile applications (“App”). This Privacy Policy describes how FinanceCreation treats your Personal Information when you use or evaluate our Site, App and/or Services.
For the purpose of this Privacy Policy, a “User” is an individual who creates an account on our Site or App to use our free financial planning software and/or to understand or evaluate our Services; and a “Client” is an individual who signs our Client Agreement that entitles the Client to maintain a Cash Account, and/or has their investment portfolio managed by FinanceCreation.
Our Privacy Policy, Terms of Use and, where applicable, Client Agreement, collectively govern your use or evaluation of our Site, App and Services.
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:
Wherever FinanceCreation collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms, such as our Website Terms of Use and/or Financial Planning Terms of Use.
We collect Personal Information from Users, including but not limited to your:
In addition to the information we collect from Users as described above, Clients must provide us 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 directly from or about persons under the age of 18.
If you are under the age of 18, please do not submit any Personal Information to FinanceCreation.
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 unless regulatory obligations prevent us from doing so.
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 and Financial Industry Regulatory Authority. 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.
This Privacy Policy and these terms apply only to FinanceCreation operated Services and applications. Please note that our Site and Apps may contain links to other websites, applications, social media accounts, and information for your convenience that are not operated or controlled by FinanceCreation. FinanceCreation does not control Linked Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. FinanceCreation does not endorse or make any representations about Linked Third-Party information. Any Personal Information you choose to give to Linked Third-Parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third-parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.
FinanceCreation provides websites and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our website are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download tools, such as an application, widget or another tool, that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to FinanceCreation to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.
We may run sweepstakes and contests. The 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 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.
General. You have certain choices about the use and disclosures of your Personal Information, as set out in this Privacy Policy.
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. Clients and Users cannot opt-out of providing FinanceCreation Personal Information and continue to use the Services. Clients and Users must close their account(s) in order to opt-out of further providing FinanceCreation with Personal Information. 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 and regulatory purposes as described above.
FinanceCreation may use your Personal Information to communicate with you regarding our Services or to tell you about blog posts or Services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at [email protected]. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications, or updates to our Terms or this Privacy Policy
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.
FinanceCreation retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site, App, or Services or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.
Users may request information regarding the Personal Information we have collected about you over the last 12 months and/or 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 or an authorized representative. Please note, you must personally provide us authorization prior to us being able to process such a request if you utilize a third-party data deletion request company. 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. Furthermore, in connection with our regulatory recordkeeping obligations, we cannot delete Personal Information associated with Clients.
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 residents of California 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 the third-parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, this disclosure requirement only applies if we share Personal Information with third parties for those third-parties to directly market their own products to those consumers, and FinanceCreation does not share Personal Information with third-parties for those third-parties to directly market their own products to Users or Clients.
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 the permanent deletion of Personal Information. Users can request information related to Personal Information we have collected about them and/or request deletion of their Personal Information by following the “Retention and Deletion” procedure above.
We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.
FinanceCreation encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with FinanceCreation after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified on this page by its effective date.
This document constitutes FinanceCreation’s complete Privacy Policy for FinanceCreation and its affiliates and the Services, Site and App.
Questions and Contacting Us
If after reviewing this Privacy Policy, you would like to submit a request, opt-out or you have any questions or privacy concerns, please contact us by email at [email protected] or via physical mail at:
FinanceCreation Corporation
261 Hamilton Ave
Palo Alto, CA 94301