This Privacy Policy, which is incorporated into our Terms, outlines our privacy practices in connection with your use of our websites and any related applications and services (together, the “Website” or “Service”).
What does this Privacy Policy cover?
This Privacy Policy explains how we collect, use, and disclose information. It only applies to the service where we control data collection and use. It does not apply to any third-party websites, actions, or offers (together, “Third-Party Services”), regardless of links or connections through the Website. We do not control Third-Party Services, which have separate privacy practices.
We collect and use information primarily to provide and improve the Service. For example, when you visit our Website, you may provide information to us to use the Service, and we may also generate technical device and cookie data. This allows us to provide and market our offerings.
When do we collect your information?
Generally, we collect personal information when you provide it, such as through a Website submission or when you contact us. Like many websites, we also obtain technical and device information when you visit or use the Website. Further, we may collect information when it is relevant to the Service, including from third parties or public records, such as if you post a review about us online.
For example, if you call us or use the Website to request to be connected with an advisor, you may provide your background relevant to the Service and to connect you with a member of our Advisor Network. Further, if you click to be redirected to Third-Party Services, we may collect related data from a member of our Advisor Network as relevant to our provision of the Service.
What categories of information do we collect?
Typically, we collect information that is relevant to the Service, such as data to connect you with an applicable member of our Advisor Network. For example, we may collect your name, birthdate, relevant financial information, zip code, and contact information, such as your email address, phone number, and home location. This information is collected when you provide it to use the Service and may include personally identifiable information (“PII”) and sensitive financial data.
More specifically, we may collect the following categories of personal information:
Identifying Information, such as name, email address, and phone number.
Background Information, such as racial or ethnic origin, marital status, sexual orientation, sex, or age, some of which may include protected class data along with other categories.
Financial Information, such as investable assets, income, and net worth.
Professional Information, such as employment or education experience.
Sensitive Information, which may include the categories above.
Technical Information, such as device, internet, and network information, including data from cookies and related technologies, search and browsing history related to the Service and interaction with our marketing, and geolocation information from a device IP address.
Other Information, such as communications to us or non-personalized information like public or aggregate data. You should take caution in publicizing or uploading any sensitive or confidential information.
How is your information used?
Generally, we use information to provide and improve the Service, to personalize the user experience, and for relevant marketing.
Specifically, we may use personal information for these reasons:
Providing the Service, such as to operate and provide the Website.
Connecting You with Advisors, namely in response to your requests to be connected with a member of our network of financial advisors (“Advisor Network”). For example, when you request to be connected with an advisor and submit contact, geographic, and background information, which may include sensitive information, we may use that information to connect you with applicable potential advisors and to eliminate members of our Advisor Network for which you do not meet the eligibility criteria. Note that our collection and use of information does not guarantee that a financial advisor will provide services to you.
Improving the Service, such as to review whether other features are desired.
Personalizing the Service, such as by using cookies or other technologies to save certain data for limited time periods so you do not need to enter it again.
Communications, such as to respond to your requests or questions. This may include business-related or legal communications, replies to your inquiries, or marketing communications (which are outlined further below).
Limited Use of any sensitive data if reasonably necessary and proportionate to provide and maintain our Service or if reasonably expected, or short-term transient use if no disclosure or profiling, or for security or legal purposes.
Security and Auditing, such as to detect security incidents, protect against malicious, fraudulent, or illegal activity, and to take action if applicable. We may also use information to authenticate requests or for other security reasons.
Comply with Legal Obligations, such as to comply with a court order or subpoena or to transfer privacy requests to relevant third parties.
Marketing to You, such as to share relevant content with you using your contact information, or to deliver digital media ads, which may use information gathered through cookies and other technologies. In particular, if you provide your email address or sign up on our Website, we may send you promotional emails; and if you agree to receive calls or text messages or call us to make an inquiry, we may use your phone number for marketing calls.
Advertising, such as by reviewing user choices to determine what offers may be interesting to others or to feature public reviews or posts about us.
Other Use due to your request or consent and as authorized by law.
These uses further our business purposes as reasonably necessary and proportionate to our operations, such as provision and protection of the Service, as well as commercial purposes, such as marketing relevant offerings. We similarly process your information pursuant to our legal bases in providing and improving the Service, communicating with you, complying with our legal obligations, preventing fraud, advertising to you, promoting safety and security, responding to requests, with your consent, where necessary to perform a contract, where processing is necessary to protect your or another person’s vital or legitimate interests if not overridden by fundamental rights or freedoms, and where necessary to comply with a legal obligation.
How is your information disclosed to others?
Generally, we disclose information for the same business and commercial reasons that we collect and use information, such as to provide and improve the Service, to comply with legal obligations, and for relevant marketing.
Specifically, we may disclose information under these circumstances:
To Members of our Advisor Network, who review information you provide and that is relevant to any applicable request for financial advisor services to determine whether they may be able to assist you. In particular, we share your information with members of our Advisor Network, including, potentially, both registered investment advisors and entities which represent or employ such individuals, to facilitate your request for provision of personalized financial advice. For example, we may provide your information to these parties so that you can determine whether to engage their services. By using our Service, you are using and directing us to intentionally disclose the information you provide and to intentionally interact with these Third-Party Services, who in turn may receive compensation for connecting you.
To Service Providers or contractors, such as email or hosting services or customer support, who may review information you provide or that is part of your use of the Service to assist us in providing the Service to you.
To Legal Parties, who may require disclosure of data as authorized by applicable law in response to a subpoena, court order, or other legal process. This may include transfer of information to relevant third parties to fulfill a privacy or other legal request. We may also disclose information if we believe it is necessary to prevent or remedy illegal or harmful misconduct, including to law enforcement or to our legal, professional, or other advisors.
To Marketing Partners, affiliates, platforms, advertisers, or third parties, who may obtain information you provide as well as device, internet, and technical information, to provide personalized and other advertisements that may be of interest to you, including through email if you subscribe to our content.
To Third Parties or the Public, if the information is public, such as a review posted about us online, or if it cannot reasonably identify or be linked to you, such as aggregate data used to evaluate the Service and users as a whole.
To Related Parties if we are involved in an acquisition, merger, sale, or similar transaction, in which case we may transfer or assign your information.
To Others due to your request or consent and as authorized by law.
For Data Selling or Sharing if and as outlined to you, such as in this Privacy Policy, for the purposes described. In particular, certain transfers of data to members of our Advisor Network and through cookies and similar technologies may be considered data selling or sharing under certain laws (which may or may not apply to us or to you under various legal thresholds). You may opt out of such practices by using opt-out links on our Website (which will be displayed if required by applicable legislation to certain users) or by contacting us as outlined below.
Do we use cookies or automated technologies?
We, like many websites, may use cookies (files that are placed on your computer or electronic device when you visit a website), pixels, web beacons, and similar technologies to automatically collect certain device, internet, browser, and geolocation information when you use the Website.
Collected data may include mobile device identifier or MAC address, ISP or carrier information, date and time you access the Website, the pages you visit, and whether you click on certain content or advertisements. We may use this information to personalize parts of the Service, determine when content is accessed, and customize advertisements. These technologies may include necessary and preference cookies, such as to display the Website and comply with preferences set by you, as well as analytics and advertising cookies, such as to understand how users use the Service and to deliver ads.
Specifically, we may use advertising services to display ads tailored to individual interests and provide related analytics. This may constitute data selling or sharing under certain laws. To opt-out of these practices or cross-device linking, use our opt-out links or visit the websites referenced above. For example, we may use Google cookies and tools to provide and improve our Service and for analytics and advertising. For more information, visit Google’s policies, https://policies.google.com/technologies/cookies?hl=en-US, or install the opt-out add-on at https://tools.google.com/dlpage/gaoptout.
You may opt out of cookies or change your cookie settings in your internet browser or disable similar tracking technologies in your mobile phone or other device. Resources for these technologies and opting out include: https://www.allaboutcookies.org/, www.aboutads.info/choices and https://youradchoices.com/appchoices.
Note the Website does not currently respond to DNT requests (DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked).
Do we collect information about children?
We do not knowingly collect personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about children under the age of 13, we will delete that information.
How is your information protected and retained?
We process and transfer data to the United States. While we use reasonable security measures and tools that are designed to be a security safeguard, and we take data security seriously, no system or website can be 100% secure. You should not expect that information communicated using our Service or the internet generally will be secure. You are responsible for maintaining the security and confidentiality of your accounts and devices and should immediately notify us if you believe there has been a relevant security breach.
We will retain your information for the length of time necessary to fulfill the business and commercial purposes outlined in this Privacy Policy or as otherwise authorized by law, considering these factors: ongoing services or open requests; legal obligations for data retention; and other relevant considerations, including legal agreements and any pending inquiries.
What are your privacy rights?
Certain users have privacy rights, such as to access and delete personal information we have collected, as outlined further below. If you have a specific privacy request regarding your information, please contact us with your name and email address (or other identifier used with the Service) using our contact information below. To protect user privacy and security, we may require that you, or your agent if applicable, verify the identity of the requestor.
Access your information, including for certain users such as California residents, to know the categories of information we have collected and the sources, our related business and commercial purposes, the categories of third parties to whom data is disclosed, and the information we have collected about you. Under California’s “Shine the Light” law, California residents who provide personal information may request information regarding disclosure of personal information to third parties for their direct marketing purposes.
Delete your information, subject to certain legal limitations.
Amend your information if it is inaccurate.
Limit the processing of certain information or any automated decision making.
Opt Out of certain practices, such as any selling or sharing of information, or marketing communications. For more information, use the relevant opt-out links on the Website or follow the prompts in the related communications. If you opt out of advertisements, we may still send you non-promotional messages, such as related to your use of the Service or legal updates.
Non-Discrimination for assertion of your privacy rights or filing a complaint.
What is our contact information?
You can contact us by using our Contact Form or by emailing us at contact@friendswealthmanagement.com. We may store information related to your requests or communications and disclose it if needed to process your request.
How do we modify our Privacy Policy?
The version of this Privacy Policy posted on the Website is the current version, and if any modifications are made, we will post the then-current version. By continuing to access or use our Service after any modifications are posted, you agree to be bound by the modifications. Any modified Privacy Policy will only apply as of the updated date of the Privacy Policy.
