Policy Effective Date: Effective July 9, 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.
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:
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, although you are not required to do so. In enabling this functionality, retrieves the User or Client account information maintained by such third-party financial institutions with which the User or Client has an existing customer relationship (“Account Information”), as described in this section.
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.
We may use third-party vendors to verify your identity by determining whether the “selfie” you provide matches the photo in your government-issued identity document. The information collected from your photograph may constitute biometric information in some jurisdictions. Where required by law, we will seek any required permissions from you prior to any such collection. We require our third-party vendors who support identity verification to agree to destroy any potential biometric data that is created or gathered for purposes of verifying your identity no more than 90 (ninety) days after its collection.
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. 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.
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.
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.
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.
Questions and Contacting Us