Privacy Policy

Policy Effective Date: Updated November 28, 2017

Your Privacy Matters

Wealthfront’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.

We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”).

Introduction

Wealthfront Inc. and its affiliates (“Wealthfront”, “we”, “us” and/or “our”) offers financial planning and portfolio management services through an automated investment adviser service (“Service”). Our Service is made available through Wealthfront’s website, www.wealthfront.com (“Site”), or our related mobile application (“App”). This Privacy Policy describes how Wealthfront treats your Personal Information when you use or evaluate our Site, the App and/or Service or when you apply to and/or become an employee (“Employee”).

For the purpose of this Privacy Policy, a User is an individual who uses our Site or App to understand or evaluate our Service; and a Client is an individual who signs our Client Agreement that entitles the Client to have her or his investment portfolio managed by Wealthfront.

Our Privacy Policy, Terms of Use and, where applicable, Client Agreement, collectively govern your use or evaluation of our Site, App and Service.

Information Collection

The types of information we collect depend on whether you are a current or former User, Client and/or an Employee. We collect Personal Information from you when you voluntarily provide it to us. Examples of instances when we collect Personal Information include:

  • when you answer questions on the Site or in our App to determine what kind of portfolio we might recommend if you were to become a Client,
  • when you register to open an account,
  • when you contact our client service organization with questions,
  • when you become a Client, or
  • when you apply to or become an Employee.

Wherever Wealthfront collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms, such as our Terms of Use.

Information We Collect from Users

We collect Personal Information such as name, address, telephone number and other optional information you may provide, such as your age, investable assets, and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household.

We may collect your e-mail address and/or telephone number should you engage with us via our Site, App, or email or by calling our client service team.

Information We Collect from Clients

If you choose to become a Client, in addition to the information we collect from you as a User, described above, we will ask you for certain additional Personal Information, including but not limited to:

  • your and your beneficiaries full legal name, contact information, birth date, Social Security Number, citizenship;
  • your investment objectives, approximate net worth, and other regulatory disclosures that may be necessary and required by federal and certain statutory laws (see our Client Agreement);
  • account numbers and login credentials for the accounts (bank or brokerage) you choose to link to our Service, any challenge and/or security questions associated with those accounts and any information contained in those accounts. Note: if you choose to link to our Service, we may use a third-party service to aggregate your account data.

Information We Collect when Acting As a Client’s Authorized Agent

Many of Wealthfront’s Clients choose to aggregate information from accounts at other financial institutions onto their dashboard on our Site or in our App; in enabling this functionality, Wealthfront acts as an agent to retrieve the Client’s account information maintained by third-party financial institutions with which the Client a legally-binding customer relationship (“Account Information”). This information may include account balances, transactions and holdings from the linked financial institutions.

By choosing to use our Service to aggregate and analyze Account Information, you expressly authorize and direct Wealthfront, on your behalf, to electronically retrieve Account Information. Wealthfront may work with one or more third-party financial service technology providers to access and retrieve your Account Information.

Information We Collect from Employees

Wealthfront collects Personal Information from current, prospective and former Employees, their designated contact in case of a medical emergency, and beneficiaries under any insurance policy (“Employee Personal Information”). The Employee Personal Information we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, social security number, financial information related to credit checks, bank details for payroll, external brokerage account information, holdings and trading activity, information that may be recorded on a CV or application form, contact information in case of an emergency, and beneficiaries under any insurance policy. Additionally, we may collect sensitive Employee Personal Information, such as details of health and disability, including mental health, medical leave, and parental leave.

Information We Collect via the Referral Program

Wealthfront manages a referral program called “The Wealthfront Invite Program.” The program allows our clients to lower their annual advisory fee in exchange for referring other users who ultimately become a client. Participation in our referral program is free and voluntary for our Clients. By participating, you may provide us with certain information about the person to whom you refer our service, such as name and e-mail address. We treat this information like all our other Personal Information.

Information Regarding Children

Due to the nature of our business, Services and benefits are not marketed to minors. Except for beneficiary information as described above, Wealthfront does not knowingly solicit Personal Information from children under the age of 18.

If you are under the age of 18, please do not submit any Personal Information to Wealthfront.

If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files.

If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at support@wealthfront.com and we will delete such information from our files.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

  1. Anonymized or aggregated Information. Wealthfront’s Site and App automatically record certain anonymized or aggregated information about your use or evaluation of our Service. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  2. Cookies and Pixels. Similar to other technology platforms and services, Wealthfront uses cookies, a small piece of computer code that enables our Web servers to “identify” Users, each time an individual initiates a session on our websites. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your own hard drive at any time. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.
  3. Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
  4. Site and App Activity. Wealthfront may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
  5. “Do Not Track” Technology. We do not collect personal information about your online activities over time and across different web sites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different web sites or online services.

How we use Information

User Personal Information

We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your personal information a number of ways, including research, internal analysis, and analytics.

Client Personal Information

Wealthfront stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services and provide our Service to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client.

Additionally, we may share the information required to become a Client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you.

Mobile Computing

Wealthfront provides websites and online resources that are specifically designed to be compatible and used on mobile computing devices. Mobile versions of our Site may require that you log in with an account. In such cases, information about use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Wealthfront to enable you to access your account information and to enable us to track use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. We may use Personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.

Employee Personal Information

We acquire, hold, use and process Employee Personal Information for a variety of business purposes including but not limited to:

  • Human Resources administration and communication
  • Payroll and the provision of benefits; compensation, including bonuses and long term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs
  • Workflow management, assigning, managing and administering projects;
  • Performance and employee development management;
  • Organizational development and succession planning;
  • Emergency contacts and services;
  • Processing of employee expenses and travel charges;
  • Monitoring compliance with regulatory requirements.

If an employee is also a User or a Client, the provisions hereunder related to Users and Clients will apply to such information in those circumstances.

Information Sharing and Onward Transfer

We will not sell, rent, or trade your Personal Information (whether you are a current or former Client) to any nonaffiliated third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use.

There are certain circumstances, in which we may share your Personal Information with nonaffiliated third parties without further disclosure to you. For example, from time-to-time, we hire third-parties to perform certain business and technology related functions (e.g., mailing information, database maintenance and payment processing). In the case we hire a third party to perform a function of this kind, we endeavor to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your information.

No Renting, Selling or Trading Out List

We will never rent, sell or trade your Personal Information to anyone. Ever.

Your Choices and Opting Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

You may decline to provide personal information to Wealthfront. Declining to provide personal information may disqualify you for Wealthfront services and Site features that require certain personal information.

Opting-Out - Obtaining and Withdrawing Consent

Where you have consented to Wealthfront’s use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us by email or phone via the contacts indicated in Section X below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

Prior to disclosing sensitive Personal Information to a third-party or processing sensitive Personal Information for a purpose other than its original purpose or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the law or contract.

We will only use Employee Personal Information only for employment-related purposes. If we intend to use this Employee Personal Information for any other purpose, we will provide the Employee with an opportunity to opt-out of such uses.

Restricting Communications

Wealthfront may use your Personal Information to communicate with you regarding our Service or to tell you about blog posts or Services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at support@wealthfront.com. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.

Accessing Your Personal Information

Users or Clients may contact us at support@wealthfront.com to request information about how to access your Personal Information.

  • Wealthfront provides all Clients with continuous access via the Site to prompt reporting information about Account status, securities positions and balances.
  • Clients can access or amend their Personal Information at any time by signing in your Wealthfront account via our Site or mobile App.
  • Your requests will be processed in line with local laws, including without undue delay and in accordance with any required time frames. Although Wealthfront makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor provide you with an explanation of why that determination has been made within one month of the request, and a contact point for any further inquiries and any other legally required information. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Retention and Deletion

Wealthfront retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Sites or App or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

You may request deletion of Personal Information by contacting us at support@wealthfront.com and providing us enough information to identify your account and prove that you are the owner of the identified account. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies.

Security

Wealthfront takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot ensure or warrant the security of any information you transmit to us.

Other Important Information

Advertising

We do not allow third-party advertising on our Site or Apps.

Social Media and Links to Other Web Sites and Applications: “Linked Third-Party”

This Privacy Policy and these terms apply only to Wealthfront operated services and applications. Please note that our Sites may contain links to other websites for your convenience and information that are not operated or controlled by Wealthfront. Wealthfront does not control Linked Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Wealthfront does not endorse or make any representations about Linked Third-Party websites. Any Personal Information you choose to give to Linked Third-Parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third-parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

California Privacy Rights

California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third- parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Wealthfront does not share Personal Information with third-parties for their own marketing purposes

Changes to this Privacy Policy

We may update this Privacy Policy from time to time as we deem it necessary at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.

Wealthfront encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with Wealthfront after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified at the bottom of the page by its effective date.

This document constitutes Wealthfront’s complete Privacy Policy for Wealthfront and the Service, Site and App.

Questions and Contacting Us

If after reviewing this Privacy Policy, you would like to submit a request, opt-out or you have any questions or privacy concerns, please contact us by email at support@wealthfront.com, by phone at 844.995.8437 or via physical mail at:

Wealthfront Inc.
900 Middlefield Road
Redwood City, CA 94063