THE INFORMATION WE COLLECT.
We collect data to provide the products and services you request, ease your navigation on the App, communicate with you, and improve your experience using the App. Some of this information is provided by you directly to us, such as when you purchase our products or services. Some of the information is collected through your interactions with the App. For example, we use tracking technologies such as cookies and pixels (discussed below in Section 1.2), and other usage data such as error reports. Some of the information is collected from your use of, and interactions with, us and others on social media, including Twitter®, Facebook®, YouTube®, Instagram®, Snapchat®, TikTok®, and LinkedIn® (collectively “Social Media”). The data we collect depends on the products, services, and features of the App that you use, and includes the following:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Please note: Some Personal Information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
G. Geolocation data.Physical location or movements.
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other Personal Information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information does not include: Publicly available information from government records.De-identified or aggregated consumer information. Additionally, the following types of personal information are excluded from the CCPA’s scope: Certain health or medical information otherwise covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Automatically Collected Usage and Device Information.
Similar to other apps and websites, we use tracking technologies to automatically collect certain technical information from your web browser, mobile, or other device when you visit or use our App. This data may include, without limitation, your IP address, browser type and language, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this data, described in more detail below, allows us to provide more personalized services to you and to track usage of the App.
Similar to other websites, we use tracking technologies (such as cookies) to automatically collect certain technical information from your web browser, or device you use when you visit our App. This data may include your IP address, browser type and language, referring and exit pages and URLs, other browser history, platform type, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of your visits. Our collection of this information allows us to improve your user experience in various ways, including to personalize our display of the App, to provide better technical support to you, and to track usage of the App. Please note: If you restrict, disable, or block any or all cookies from your web browser or device, the App may not operate properly and you may not have access to certain services or parts of the App. For more information regarding your online tracking choices, please refer to Section 7 (Safety, Information Security Measures, and Retention). We will not be liable for any interruption in, or inability to use, the App or our services or degraded functioning thereof, when caused by your settings or choices regarding cookies.
Pixels and Similar Technologies.
We may use pixels (also known as web beacons or web bugs) to automatically record certain information about how you engage with us or otherwise interact with the App, to help deliver cookies on our App, or to count users who have visited the App. We may also include pixels in our promotional e-mail messages or newsletters to determine whether you open or act on them. Pixels are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements, and related information of App users. Unlike cookies, which are stored on a user’s computer hard drive, pixels are invisible and embedded on web pages or in HTML-based emails. The data we receive through pixels allows us to promote the App effectively to various populations of users and to optimize external advertisements about the App that appear on third-party websites.
Financial Institutions; Investment.
You may choose to link your account on the App to your financial accounts, such as debit or credit accounts, or to open an investment account with a third-party provider via the App. When you do so, we will collect transaction and other related data from your financial institutions or third-party investment services provider in order to provide you our services, and to improve our App or products and services. Please be aware that your financial institutions and any third-party investment services providers have their own privacy policies and those policies will apply to you regarding how they handle your Personal Information. We encourage you to review their policies as applicable.
Information from Other Sources.
We may obtain both personal and non-personal information about you from unaffiliated business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness and also helps us better tailor our interactions with you.Location Information. We collect precise geolocation data from you or your device, as well as your address information (e.g., billing address), when you set up an account or order our products or services. We also collect and use information about your general location (e.g., the state in which you live) and can infer your approximate location based on your IP address in order to track our general App usage or to tailor any pertinent aspects of your user experience to the region where you are located.
Information about Others.
We display personal testimonials of satisfied customers on our App in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at the email address listed in Section 12 (Contact Information).
Third Party Analytics Providers.
HOW WE USE YOUR INFORMATION.
We may use or disclose the Personal Information identified above for one or more of the following business purposes (“Business Purpose”): To fulfill or meet the reason you provided the information (e.g., to help provide products and services to you). To personalize, improve, and develop our App and the products and services we provide through the App, and to deliver content and product and service offerings relevant to your interests, including offers and advertisements through third-party sites and via email.To provide features or functionalities on the App.To create, maintain, customize, and secure your account with us.For marketing and promotions.To provide you with support, to communicate with you, and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.To help maintain the safety, security, and integrity of our App, services, databases, other technology assets, and business.For testing, research, analysis, and product development, including to develop and improve our App and services.To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.To prevent illegal activity, fraud, and abuse.As described to you when collecting Personal Information.To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred or liquidated.
When you create an account with us or otherwise provide us with your email address we may, as permitted by applicable law, use your email address to send you App-related notices (including any notices required by law), updates, news, and marketing messages. Marketing communications you receive from us by email will typically include an unsubscribe link or instructions allowing you to opt out of receiving future marketing emails or to change your email preferences. Please remember that even if you opt out of receiving marketing e-mails, we may still send you emails with other information such as important service information related to your account and the App. If you correspond with us by email, we may retain the content of your email messages, your email address, and our responses.
Non-Personally Identifiable Information.
We may use non-personally identifiable information, such as anonymized and/or aggregated App usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the App, including to develop new features, functionality, and services, to conduct internal research, to better understand App usage patterns, to resolve disputes, to troubleshoot problems, to fulfill user requests, or for security and compliance purposes. Any non-personally identifiable information that is combined with Personal Information will be treated by us as Personal Information.
OUR INFORMATION SHARING PRACTICES.
We disclose Personal Information for a Business Purpose to various third parties, including:
If you purchase or pay for products or services via the App, the transaction may be handled by our service providers or third parties responsible for processing or financing your transaction (“Payment Processors”). Please be aware that Payment Processors have their own privacy policies and those terms will apply to you regarding how that Payment Processor handles your Personal Information. Depending on your purchase, it may be made via the App or you may be re-directed to a third-party site for payment. If your purchase is made via the App, in order for the Payment Processor to process or finance your purchases, we may require payment, credit card, or other credit-related information. If you are re-directed to a third-party site for your purchase, please be sure to review any linked policies provided during payment processing as they will apply to you.
Investment Account Operators; Brokers.
If you choose to open an investment account with a third-party provider via the App or otherwise link your account on the App to other finance and investment apps, websites, or tools, we will share your information with that third party in order to provide the services you requested.
We reserve the right to disclose all information collected via the App, internally, to affiliates, or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion we may disclose information to government regulators, law enforcement authorities, or alleged victims of identity theft. We will notify you in the event of a government or legal request for your information unless otherwise prohibited by law.
We share or make your information available, including any Personal Information, in the circumstances described below.
Disclosures of Personal Information in the Last Twelve Months.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a Business Purpose, as more fully described in Section 4 (How We Use Your Information): Category A: Identifiers.Category B: California Customer Records personal information categories.Category C: Protected classification characteristics under California or federal law.Category D: Commercial information.Category F: Internet or other similar network activity.Category G: Geolocation data.Category H: Sensory data.Category I: Professional or employment-related information.Category K: Inferences drawn from other personal information. We disclose your Personal Information for a Business Purpose to the following categories of third parties: Analytics Providers.Social Media.Advertisers and other third party marketing service providers.Financial institutions and other investment services providers. Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the App. Please note: Affiliated persons or our third party service providers may augment, extend, and combine non-personally identifiable information with data from additional third party sources in order to assist us in our operation of the App.
Sales of Personal Information in the Last Twelve Months.
Under the CCPA, the sale of Personal Information means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration” (Cal. Civ. Code § 1798.140(t)(1)). We make your Personal Information available to third parties, subject to your right to opt-out. In the preceding twelve (12) months, we have made available the following categories of Personal Information: Category A: Identifiers.Category B: California Customer Records personal information categories.Category C: Protected classification characteristics under California or federal law.Category D: Commercial information.Category F: Internet or other similar network activity.Category G: Geolocation data.Category H: Sensory data.Category I: Professional or employment-related information.Category K: Inferences drawn from other personal information. We make your Personal Information available to the following categories of third parties: Analytics Providers.Social Media.Advertisers and other third party marketing service providers.Financial institutions and other investment services providers. Affiliated persons or third-party service providers assisting us in the operation, management, improvement, research and analysis of the App
YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION.
You Can Choose Not to Provide Personal Information.
You may always decline to provide your Personal Information to us. Providing Personal Information is not required, but if you choose not to provide certain Personal Information to us, some of your experiences may be affected (for example, you must provide your name and certain contact information in order to register for an account with us or to purchase products).
You May Decline Other Requests.
CCPA Access, Deletion, and Opt-Out Information.
Right to Access Specific Information and Data Portability Right.
If you are a resident of California, as defined in the CCPA, you may have the right under the CCPA to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you: The categories of Personal Information that we have collected about you.The categories of sources for the Personal Information that we have collected about you.Our business or commercial purpose for collecting or making available that Personal Information.The categories of third parties with whom we share that Personal Information.The specific pieces of Personal Information that we have collected about you (also called a data portability request).If we disclosed your Personal Information for a Business Purpose, the Business Purpose for which such Personal Information was disclosed, and the Personal Information categories that each category of recipient obtained.If applicable, (i) the categories of your Personal Information that we have made available for valuable consideration; (ii) the categories of third parties to whom such Personal Information was made available; and (iii) the category or categories of Personal Information that we have made available to each category of third parties.
Right to Delete.
If you are a resident of California, as defined in the CCPA, you may have the right under the CCPA to request that we delete your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or vendor(s) to: Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.Debug products to identify and repair errors that impair existing intended functionality.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.Comply with a legal obligation or legal order.Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Visiting https://wealthstack.us/access-or-deletion-requestSending us an e-mail at firstname.lastname@example.org Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make such a request for access or data portability twice within a twelve-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Right to Opt-Out.
If at any time, we make your information available to third parties other than for a Business Purpose and you are 16 years of age or older, you may have the right under the CCPA to direct us not to do so (the “right to opt-out”). We do not make available the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in may opt-out at any time. To exercise the right to opt-out or right to opt-in, you (or your authorized representative) may submit a request by sending an email to the contact email listed in Section 12 (Contact Information) or by completing and submitting the form located here: [INSERT OPT-OUT FORM]. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize certain information sharing practices. However, you may change your mind and opt back in at any time by sending us an e-mail at the contact email address listed in Section 12 (Contact Information). We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services.Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.Provide you a different level or quality of goods or services.Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Online Tracking Choices.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services of the App may not function properly if your cookies are disabled. Similarly, if you choose to delete session objects from our App, you may not be able to access and use all or part of the App or benefit from some or all of the information or features and services offered. Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information from that browser. Not all browsers offer a DNT option, and DNT signals are not uniform. For this reason, many websites, including the App, do not respond to DNT signals.
Gramm-Leach-Bliley Act (GLBA) Notice.
As a part of your use of our products and services, we may collect information that is subject to the GLBA. For more information regarding our handling of such information, please visit our GLBA Notice (located at [INSERT GLBA NOTICE LINK]).
SAFETY, INFORMATION SECURITY MEASURES, and retention.Security.
We use certain physical, electronic, procedural, administrative, and technical safeguards designed to preserve the security and confidentiality of your Personal Information that we maintain in connection with your use of the App. For example, we encrypt data with secure sockets layer (SSL) or similar technologies when we transmit your data. This, however, does not guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, administrative, or technical safeguards. If any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you when required by applicable laws and regulations.
We or our third party hosting providers store Personal Information in operating environments that are safeguarded against public or unauthorized access and protected from internal access with physical and technical security measures. While these measures are helpful to safeguard your Personal Information after we receive it, no transmission of data over the internet is 100% secure.
NOTICE TO USERS OUTSIDE THE UNITED STATES.
Please be aware that we are headquartered, operate in, and only sell products and services in the United States. The App is governed by United States law. If you are accessing our App or services from outside of the United States, your information may be transferred to, stored, and processed in the United States where our servers may be located. The United States might not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE APP, COMMUNICATING WITH US VIA MAIL, EMAIL, OR TELEPHONE, OR OTHERWISE PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF YOUR INFORMATION IN THE UNITED STATES.
CALIFORNIA SHINE THE LIGHT LAW.
California Civil Code § 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed Personal Information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to request this information, please send an e-mail with “California Privacy Rights” in the subject line to the contact email address listed in Section 12 (Contact Information).
The App is not directed at or intended for use by children, and we do not knowingly collect Personal Information directly from users under the age of 13 or from other websites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will not knowingly request or collect Personal Information from any child under age 13 without obtaining the required parental consent. Please visit http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online.
While the App is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at to the email address listed in Section 12 (Contact Information). When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (i) federal or state law requires us or a third party to maintain; (ii) was not posted by you; (iii) is anonymized so that you cannot be identified; (iv) you don’t follow our instructions for removing or requesting removal; or (v) you received compensation or other consideration for providing the content or information. Removal of your content or information from the App does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it no longer visible to other users and the public.