LAST UPDATED: 2/3/2020
We are committed to the responsible management of consumer information and abide by all rules, both ethical and legal, with respect to the use of consumer information.
The 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.
2. PERSONAL INFORMATION
- Full legal name
- Mailing address
- Telephone number(s)
- E-mail address
- Transaction information
- User content
- Any other non-public information about you that is associated with or linked to any of the foregoing information
2.1 HOW WE COLLECT PERSONAL INFORMATION
We collect information from users who access our Website or use our Services in order to provide the Services to you and to help us learn more about the use of the Website or Services. We collect Personal Information that you submit to us voluntarily at registration and in the course of your use of the Website or Services. To access certain Services, you are required to create an account and provide your name, address, email address, password, birthday, social security number, as well as information about your retirement accounts and transactions, including but not limited to account balances, holdings, and inquiries. We collect and store information contained in your communications with us via email or other means. 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.
2.1.1 Authorized Representatives
2.1.2 Third Party Accounts
We may require you to provide account credentials for your third party accounts, including your 401(k) provider account or any other accounts necessary for us to perform the Services. We will use such third party account credentials solely to provide the Services requested by you. The Website allows you to connect with third party accounts through the Services. To provide us authorization to access your third party account information, you must log in to the third party account directly through the Services. To revoke our access to any third party account, you must contact the third party account provider.
2.1.3 Third Party Payment Processors
2.2 HOW WE USE PERSONAL INFORMATION
We may store and use your Personal Information in order to:
- Identify you as a user in our system
- Verify your identity
- Facilitate the creation of, secure, and administer your account
- Provide you with Services, including personalizing the Services for you and tailoring the features and content of the Services to you
- Provide you with customer support, respond to your requests, and troubleshoot and resolve problems
- Market our products and services, as well as third party products and services that we believe may interest you
- Verify your compliance with your obligations in any agreement(s) between you and us
- Improve the quality of the Website and the Services
- 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.
2.3 HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose certain Personal Information to:
- Third parties to whom you ask us to send Personal Information, which may include 401(k) providers, authorized brokers, and authorized investment advisors;
- Third parties, when necessary to effect the transactions and provide any services that you authorize;
- Third parties who refer you to our Services;
- Third party service providers who help us provide the Services or the Website;
- Third parties assessing our compliance or to complete third-party financial, technical, and legal audits of our operations;
- Our attorneys, accountants, and auditors;
2.4 RIGHTS REGARDING YOUR PERSONAL INFORMATION
Certain information is necessary for us to provide the Website or Services, and your deletion of such necessary information will interfere with or prohibit your use the Website or Services. You may request that we delete your Personal Information. In some instances, we may be required (by law or otherwise) to retain this information and will comply with your deletion request only after we have fulfilled such requirements. Any deleted Personal Information is removed from our active database, but may remain in our archives.
We will communicate with you primarily via email. You can opt out of receiving these emails by changing your account settings or by clicking “Unsubscribe” at the bottom of any email. If you unsubscribe or opt-out, we may still send you information regarding your account, the Website, and Services.
2.5 SECURITY OF YOUR PERSONAL INFORMATION
We are committed to the security of your Personal Information and use industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. While we make every effort to ensure the integrity and security of your Personal Information, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information.
3. ANONYMOUS INFORMATION
3.1 ANONYMOUS INFORMATION COLLECTED BY OUR SERVERS
We automatically gather certain information and store it in log files. Our servers are hosted by a third party service provider and collect information from you, including but not limited to your:
- Browser type
- Operating system
- Internet Protocol (“IP”) address
- Geographic location
- Date and time stamp for your visit
- Clickstream data
- Referring and exit pages
This information is used for purposes such as: Website administration, trend analysis, and tailoring the Services to our users’ needs.
3.1.1 Log Files
We automatically gather certain information and store it in log files. This information includes:
- IP addresses
- Browser type
- Internet service provider (“ISP”)
- Referring and exit pages
- Operating system
- Date and time stamp
- Clickstream data
This information is used for purposes such as: Services administration, trend analysis, track users’ movements around the Services, and tailoring the Services to our users’ needs.
3.2 HOW WE USE ANONYMOUS INFORMATION
3.3 HOW WE DISCLOSE ANONYMOUS INFORMATION
We reserve the right to disclose Anonymous Information publicly without restriction.
4. INFORMATION COLLECTED AUTOMATICALLY
We automatically collect certain information when you use our Website or Services, which may include:
- Device identifiers
- IP address
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Transaction information (e.g. transaction amount, date and time of transaction)
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs)
- Location information (e.g. IP address, zip code)
- Other data (e.g. access times, hardware and software information)
When a person visits our Website, 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 Website.
5. INFORMATION DISCLOSED TO THIRD PARTIES
6. CALIFORNIA RESIDENTS
California Consumer Privacy Act of 2018 (“CCPA”)
California residents have the right to request and receive information regarding our data practices and the third parties to whom we have disclosed their Personal Information in the prior calendar year, including the type of information disclosed, the purpose for disclosure, and the specific pieces of Personal Information we have collected about you.
California residents have the right to request that ProNvest delete all of the Personal Information associated with them. ProNvest will respond to deletion requests within forty-five (45) days. ProNvest is not required to delete your Personal Information under certain circumstances, including circumstances where we are legally obligated to retain the information or if the information is needed to defend a legal claim. ProNvest will process all requests in accordance with its legal obligations under the CCPA, taking into account any exceptions.
Please note that if you request deletion of your Personal Information, you may no longer have access to certain of our products or services.
Submit a Request:
You may submit your request for an electronic copy of Personal Information (by you or your verified authorized representative) or for deletion of your data to us via email at: email@example.com.
7. DO NOT TRACK
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Services.
9. CONTACT US