Policy Effective Date: Updated November 28, 2017
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.
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:
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.
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:
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.
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.
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.
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 email@example.com and we will delete such information from our files.
Other means by which we collect Personal Information include the following:
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.
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.
We acquire, hold, use and process Employee Personal Information for a variety of business purposes including but not limited to:
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.
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.
We will never rent, sell or trade your Personal Information to anyone. Ever.
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.
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.
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 firstname.lastname@example.org. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.
Users or Clients may contact us at email@example.com to request information about how to access your Personal Information.
You may request deletion of Personal Information by contacting us at firstname.lastname@example.org 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.
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.
We do not allow third-party advertising on our Site or Apps.
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
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