Last Updated: August 21, 2019
Wealthtender is an independent platform (as modified from time to time, the “Wealthtender Community”) dedicated to helping people (“Participants” or “you”) reduce financial stress, improve financial wellness and increase wealth through financial articles and other content (the “Wealthtender Content”) provided by various financial writers (the “Contributors” or “you”) .
For the purposes of the GDPR, Wealthtender is considered the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a Delaware corporation registered in the United States with an office at Wealthtender, Inc., 2003 Chilton Road, Houston, TX 77019.
The GDPR applies to you if you reside in the European Economic Area (an “EEA Resident”).
This policy describes the types of personal data and other information that we may collect from you or that you may provide when you publish or access any Wealthtender Content or access or use the Wealthtender Community, the Site, the other Wealthtender Services or any of the other features, functions, services, and products, including our partners’ services and products, and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to personal data and information we collect or may collect:
- In accessing and using the Site.
- In publishing or accessing any Wealthtender Content.
- In registering to use and to create an account for the Wealthtender Community.
- In accessing and using the Wealthtender Community and the other Wealthtender Services.
- In e-mail, text and other electronic messages sent through or use of the Wealthtender Community and the other Wealthtender Services.
- When you send any content through the Wealthtender Community or any of the other Wealthtender Services.
- Through services provided to us or to you by third-party companies, financial advisors, agents or contractors.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Wealthtender or any third party; or
- Any third party, including through any link that may be accessible from or on the Wealthtender Community, the Site or any of the other Wealthtender Services.
Minors under the Age of 18
None of the Wealthtender Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Wealthtender Community or any of the other Wealthtender Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Wealthtender Services or any of its features or register on the Site, use any of the interactive or public comment features of any of the Wealthtender Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com.
Information We Collect About You and How We Collect It
We collect or may collect several types of information from and about Participants, Contributors and the other users of the Wealthtender Community, the Site and the other Wealthtender Services, including:
- Information by which you may be personally identified, including personal data such as name, e-mail address, home address, phone number and birthday;
- Information that you provide when registering and creating an account;
- Information that is about you but individually does not identify you, such as IP address and date and time of visit;
- Billing information, including your credit card number, the address for billing and the billing contact information;
- Analytics or usage information and details such as when you use the Wealthtender Community, the Site or any of the other Wealthtender Services, information about your internet and mobile connections, and information collected through cookies.
- The Wealthtender Content that you publish on the Wealthtender Community;
- Any other content you provide through the Interactive Services, including any comments or postings through the Wealthtender Community and the other Wealthtender Services, any information about that content, such as if the recipient has viewed the content, replayed the content, interactions with the content, logs of users that accessed the content and metadata or statistics associated with the content.
- Usage details and information, including how you communicate with other users of the Wealthtender Community, the Site, and the other Wealthtender Services, such as the time, date, sender and your interactions with messages (such as when you open a message);
- Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);
- Information that you provide by registering or creating accounts on or through the Wealthtender Community and the other Wealthtender Services, including information provided in connection with registering to access and use certain parts of the Wealthtender Community;
- When you report a problem with the Wealthtender Community, any Wealthtender Content and any of the other Wealthtender Services;
- Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
- Details of transactions you carry out through the Wealthtender Community, the Site and any of the other Wealthtender Services.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through or use the Wealthtender Community, the Site or any of the other Wealthtender Services.
- From third parties, such as our business partners and other third parties that provide us or you with certain services.
Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.
Now or in the future, the Wealthtender Community and/or the other Wealthtender Services may also contain chat rooms, message boards, forums, bulletin boards and other interactive features (collectively, “Interactive Services”) that allow users to post, submit, publish, display or transmit to other users. Any information that you post on and transmit to others through any of the Interactive Services is at your own risk. We cannot control the actions of other users of these Interactive Services with whom your information is shared. Therefore, we cannot and do not guarantee that any such information will not be viewed, downloaded or shared by unauthorized persons.
We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.
We do not Engage in Automated Decision-making without Human Intervention
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
The technologies we use for automatic data collection may include:
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals
Third-party Responsibilities and Services.
We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including, web hosting, financial coaches, personal finance writers, application and data base servers, payment processing, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. These Services Providers may have adopted their own privacy policies, which are not subject to control by Wealthtender. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at firstname.lastname@example.org. The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service.
As a convenience to you, we may also provide links to other third-parties from within the Wealthtender Services. If you click on one of these links, you will be redirected to that third-party’s site (via affiliate cookies) and such third party may also transmit cookies to you. We do not have any control over that or how they collect, use, maintain, protect and disclose your information. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any the Wealthtender Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.
The Site is hosted on WP Engine. WP Engine collects information about the website visitors to provide the service, analyze trends in the aggregate, and administer the site. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
DoubleClick: We may use Google Analytics and Google Ads remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.
Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.
DoubleClick: We use “Google Ads” remarketing codes to log when users view specific pages or take specific actions on the Site. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out or the Network Advertising Initiative opt-out.
Google Webmasters Tools
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal data:
- To enable you to publish the Wealthtender Content.
- To provide you access and use of the Wealthtender Community and the other Wealthtender Services and the content and the other products and services that you request from us.
- To provide the Site and the content that is on it to you.
- To provide you information about the Wealthtender Community.
- To process and complete transactions, including registration and the creation of an account for the use of the Wealthtender Community and the other Wealthtender Services and send you related information.
- To provide technical and other support to you.
- To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, the Wealthtender Community and the other Wealthtender Services, and our partners.
- To enable Service Providers to perform certain responsibilities and provide certain services in connection with the Wealthtender Community and the other Wealthtender Services and our business and operations.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account and the Wealthtender Community.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Wealthtender Community, the Site and the other Wealthtender Services.
- To enhance the safety and security of all of the Wealthtender Services.
- To verify your identity and prevent fraud or other unauthorized or illegal activity.
- To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites.
- To perform targeted and other advertising on third party websites.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Wealthtender Community and the other Wealthtender Services, and to deliver a better and more personalized service, including enabling us to:
- Estimate our audience size and better understand usage patterns.
- Store information about your preferences, enabling us to customize the Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Site and the other Wealthtender Services.
Storage and Transfer of Your Information
We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Site, the Wealthtender Community, any Wealthtender Content or any of the other Wealthtender Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Wealthtender and you. By allowing Wealthtender to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.
Although users from all over the world may access the Site, the Wealthtender Community, the Wealthtender Content and the other Wealthtender Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To Service Providers, contractors and other third parties we use to support the Wealthtender Community and the other Wealthtender Services and our business and operations.
- To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Wealthtender’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Wealthtender about users of the Wealthtender Community and the other Wealthtender Services is among the assets that may be or are actually transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your data information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply the Terms and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wealthtender, Participants and/or others.
Choices About How We Use and Disclose Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
- Promotional Offers from Wealthtender. If you do not wish to have your e-mail address/contact information used by Wealthtender to market or otherwise promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email.
We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.
Our Legal Bases for Handling Your Personal Data
GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:
- Performance of a contract: In most cases, we collect and use your personal data and other information to meet our obligations under a contract to which you are a party or pursuant to which we are providing services to you. For example, when you use the Wealthtender Community or the other Wealthtender Services, we will use your personal data to respond to your requests and to provide you with the Wealthtender Services.
- Legitimate interests: We may use your personal data information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are overridden by the interests or fundamental rights and freedoms of the affected individuals) including:
- Analyzing and improving the Wealthtender Community, the other Wealthtender Services and our business
- Providing the services in connection with the Wealthtender Community and the other Wealthtender Services
- Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law.
- Consent: To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.
Accessing and Correcting Your Personal Data
You may change, correct or delete any personal data that you have provided to us by emailing us at email@example.com.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write to us at: Wealthtender, Inc., 2003 Chilton Road, Houston, TX 77019.
European Privacy Rights for EEA Residents.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.
If you are an EEA Resident and GDPR applies and we hold your personal data in our capacity as a controller, you may request that we:
- Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);
- Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);
- Update personal data that is out of date or incorrect;
- Delete certain personal data which we are holding about you; provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;
- Object to our processing of personal data;
- Restrict the way that we process and disclose certain of your information except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;
- Transfer your personal data to a third party to the extent that this is technically feasible; and
- Honor a revocation of your consent for the processing of your personal data (without retroactive effect).
We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include information that we need to keep processing for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly.
If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.
If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at email@example.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
You can exercise any of these rights by contacting us at firstname.lastname@example.org or write to Wealthtender, Inc., 2003 Chilton Road, Houston, TX 77019.
How Long We Store Your Personal Data
We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data. However, despite our efforts, no security controls are 100% effective. Wealthtender cannot ensure or warrant the security of your personal data. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The safety and security of your data also depends on you. Where you have chosen (or we have given you) a password for access to and use of certain parts of the Site, the Wealthtender Community and/or the other Wealthtender Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the Wealthtender Services. The information you share in public areas may be viewed by any other user of the Wealthtender Services.
© Copyright Wealthtender, Inc. 2019