Privacy Statement

Security Precautions
We employ various measures to secure your personally identifiable information and financial information. When you or your advisor send information to us via the Wealth Management System, communication is encrypted (for further details on such encryption, see our Security Information document). E-mails sent to us are not secure and we make no representation that any data contained in an e-mail sent to us will be secure. Thus, if your communication contains sensitive or confidential information or financial information, you should send it to us via regular mail. Except as otherwise set forth in this Privacy Statement, we restrict access to customer data to those employees who need to know that information to provide products or services to you.

Personal Information Collected
The Wealth Management System itself requires a very limited amount of personally identifiable information about you via its web sites. At this time, the Wealth Management System only requires your email address, a response to a security question, as well as necessary account information and login credentials for use with the account aggregation function. However, you or your advisor may provide extensive information concerning you, your family and your finances. 

The data collected may include, but is not limited to:
Personal Information, such as: 
  • Your name 
  • Your address
  • Your email address
  • Your employment information
  • Your investment objectives
  • Your phone number 
  • Other personal profile information
  • Other optional information you may provide, which will be used to calculate net worth 

This data is normally entered by the advisor into and stored in the Wealth Management System and used by your advisor to generate financial, retirement and estate plans.

Account Aggregation (3rd Party Accounts), including 
  • 3rd party account information you provide for Connections
  • Account login credentials you provide to be linked in Connections
  • Account security and/or challenge questions for your accounts 

The data use includes, but is not limited to:
Registration with the Wealth Management System 
  • Creating a user account 
  • Authenticating your device
  • Communicating with you about the Wealth Management System, including enhancements and service outages
Account Connections (3rd Party Accounts), including 
  • Securely collecting account balances and holdings from your financial institutions
  • Displaying consolidated information 
Customer Support
  • Addressing support requests or questions 

Disclosure of Your Personal Information
Our privacy policy is simple. We do not disclose or share the information that we collect from you or that is otherwise entered into the Wealth Management System concerning you except: (1) Wealth Management System makes all information stored in our system concerning you accessible to your financial advisor and, if applicable, the financial institution with which he or she is affiliated and/or your advisor’s alliance partners (as more particularly described in the Terms of Service); (2) to our vendors (such as hosting providers and the vendor of the account aggregation service) as necessary to provide our service to you or your advisor; and (3) as necessary to comply with legally required disclosures such as disclosures made in response to a subpoena. When we disclose your data to our vendors, it is done under an obligation of confidentiality and we only disclose as much of the information as is necessary to provide our service to you. You should refer to the privacy policies of your advisor and their affiliated institutions concerning their use and disclosure of your information.

Changing Your Information
With respect to account aggregation information, just log into the system and make whatever changes and deletions you desire to the accounts you have established. All other information can only be changed or removed through your advisor. Please contact us at, using the word CHANGE as the email subject, if you want to change information concerning you that is stored in the Wealth Management System. After confirming you are the account owner, we will make changes accordingly and alert you upon completion.

Deletion/Retention of Your Information
When requested in writing, we will remove all personal information from the Wealth Management System to the extent possible. All credentials are removed from the system. However, some historical information is retained and archived. Please contact us at, using the word CANCEL in the subject line, if you want to remove information concerning you that is stored in the Wealth Management System. After confirming you are the account owner, we will make changes accordingly and alert you upon completion.

A cookie is a piece of data stored on a user's hard drive containing information about the user. The Wealth Management System uses session cookies containing encrypted or encoded information. Session cookies allow us to process your online requests. Session cookies also help us to validate who you are after you have logged into the Wealth Management System. Session cookies exist during an online session. Session cookies become invalid when you completely close your browser software for the session in which they were created.

Other Web Sites
The Wealth Management System may contain links to other web sites. We are not responsible for the privacy practices or the content of these other web sites. If you use a link to another web site, you should consult the privacy notice for the site you visit. We have no control over the information that is submitted to, or collected by, other web sites and we are not responsible for the content of any linked site or any link contained in a linked site, or any changes or updates to such sites. This privacy statement applies solely to information collected by us or otherwise stored in the Wealth Management System.

Data Concerning Your Use of Our Web Sites
The Wealth Mangement System collects information concerning your use of our web sites including, but not limited to, the dates you logged into the web site, the areas of the web site you visited, the links to other web sites that you click and the period of time you were logged into our service provider's web site. We use this data to, among other things, understand our users activities on the sites, track data necessary for payment in relation to sponsored links and determine ways to enhance our web sites. We may share this information with third parties; provided that we will not disclose this information in a way that would disclose your identity or other personally identifiable information except in accordance with the section labeled Disclosure of Your Personal Information.

Revisions to This Privacy Statement
We may modify, amend, add or delete the terms of this Privacy Statement at any time. If we modify this Privacy Statement, we will notify you by postal mail, an email that provides a link to the modified Privacy Statement or some other method (such as by placing a conspicuous notice of the new Privacy Statement on the web site or by presenting you with a web page containing an electronic copy of the Privacy Statement) that provides fair notice of the promulgation of the modified Privacy Policy.

Effective Date; Modification
This Privacy Statement is effective as of May 22, 2012.