Last Updated: March 24, 2017
Children. Our Services and Website are not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age, and no part of our Website or Services is designed to attract people under 13 years of age. If we later learn that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Website and the Services.
How We Collect Information
In general, the Personal Information we gather enables us to provide the Services to you and helps us learn more about the use of the Website and/or Services. We collect Personal Information that you submit to us voluntarily at registration and in the course of your use of the Website and/or Services. To use certain features of the Website, we require you to create an “Account” by providing your name, email address, password and birthday. When you create an Account, we will collect information about your retirement accounts and transactions (such as purchases, sales, account balances, holdings, inquiries, etc.). When you communicate with us by sending us an email, we will collect and store any information that is contained in your communications with us. You can choose not to provide us with certain information, but this may limit the features of the Website or Services you are able to use.
We require you to provide your account credentials, including users’ names and passwords, for third party accounts, including your 401(k) provider account (“Third Party Credentials”). We will use your Third Party Credentials solely to provide the services you request. We encourage you to use user names and passwords that are different from Third Party Credentials on those accounts that you do not use with the Services.
When you order Services, our third party payment processor will collect payment and billing information in order to process the complete the transaction.
Our Relationship with Third Party Accounts. We created interfaces that allow you to connect with third party accounts, including 401(k) providers (each a “Third Party Account”), through the Services. In order to provide this authorization, you will need to log-in to that Third Party Account directly through the Services. Once authorized by you, we can access your Third Party Account information. You can revoke our access to any Third Party Account at any time by amending the appropriate settings from within your account settings on the applicable Third Party Account.
We collect the following types of Anonymous Information:
Information Collected by Our Servers. As is true of most websites, we gather certain information automatically and store it in log files. Our servers (which may be hosted by a third party service provider) collect information from you, including but not limited to your browser type, operating system, geographic location, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit, clickstream data and referring/exit pages. We use this information to analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Website or the Services again, it will recognize you.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
Disclosure – Analytics
Disclosure – Information Collected Automatically
When a person visits any of our sites, or opens one of our emails, a variety of information is automatically collected through standard web technologies. Some of this data is Anonymous Information. This data may be linked with your Account and Personal Information to better assist our clients. Automatically-collected information might include: the operating system on your computer, the type of Web browser you are using, your IP address, and the links you followed to enter and leave our site.
How We Use Information
We will use your Personal Information to:
- Identify you as a user in our system;
- Facilitate the creation of, secure, and administer your Account;
- Provide you with Services, including personalizing the Services for you;
- Provide you with customer support;
- Market to you our products and services (and those of third parties) that we believe may interest you;
- Help understand your needs and tailor the features and content of the Service to you;
- Respond to your requests, resolve disputes and/or troubleshoot problems;
- Verify your compliance with your obligations in our Client Agreement and Website Terms and Conditions;
- Improve the quality of the Website and the Services; and
- Communicate with you about the Website and the Services.
We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
How We Disclose Information
We disclose certain Personal Information:
- To third parties to whom you ask us to send Personal Information, including to 401(k) providers, brokers and investment advisors authorized by you;
- To third parties as necessary to effect the transactions and provide the services that you authorize (such as broker-dealers, custodians, independent managers etc.)
- To third parties who refer you to the Services (such as an investment advisor);
- To third party service providers who help us provide the Services or the Website;
- To third parties assessing our compliance with industry standards (such as professional licensing authorities);
- To our attorneys, accountants, and auditors;
Disclosure to Third Party Companies. We may enter into agreements with companies that desire access to Personal Information that we collect from you. AS A RESULT, WE MAY PROVIDE YOUR PERSONAL INFORMATION TO SUCH THIRD PARTY COMPANIES. BECAUSE WE DO NOT CONTROL THE PRIVACY PRACTICES OF THESE THIRD PARTY COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR PRIVACY POLICIES.
We reserve the right to disclose Anonymous Information publicly without restriction.
Controlling Your Information
Certain information is necessary in order for us to provide the Website or Services; therefore, if you delete such necessary information you will not be able to use the Website or Services. Please note that even though you may request the deletion of your Personal Information by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Terms and Conditions) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.
If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services.
We will communicate with you primarily in the form of emails. You can manage the frequency and/or opt out of receiving these communications by changing your settings on the Website and/or clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Website and Services related communications (e.g., emails related to your account or the Website). You may also sign up to receive account updates using text messaging. You can opt in or out of the service through your Account at any time.
Information Disclosed to Third Parties
Third Party Payment Processor
For online payments payouts, we use the payment services of Stripe. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to stripe privacy.
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Service.
Security of Your Information
We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security.
- 1. Source AON Hewitt and Financial Engine study, Help in Defined Contribution Plans 2006 through 2010.
- 2. Source: Schwab Corporate & Retirement Services News August 19, 2014.
- 3. Source: AARP 401k Participants’ Awareness and Understanding of fees February 2011.
- 4. Source: Schwab Corporate & Retirement Services News August 19, 2014.
- 5. Source: CNBC – Retirement: Workers to employers: Help me save! July 27, 2016.