1. Personal Information Collection
1.1 Personal Information You Provide to Us. Personal information you may provide to us through the Service or otherwise includes:
- Contact details, such as your first and last name, email address, mailing addresses, and phone number.
- Account information, such as your username and password that you set to establish an online account with us and information you store in your account.
- Business data, such as your affiliated companies or business contact details.
- Communications between advisors and clients or that we exchange, including when you contact us with questions, feedback, or otherwise.
- Financial and investment data, such as data that you choose to import or store in your account from your financial provider or another third party, information about assets and net worth, plan details, and investment-related data.
- Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Service (including name, credit card information, bank account number, billing and shipping information), and information about services you have purchased from us and other users you have engaged with.
- Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communication.
1.2 Personal Information from Other Sources. We may obtain personal information about you from other sources, such as:
- Data providers, such as information services and data licensors.
- Other users, such as the advisors or clients you connect with through the Service.
- Third party services, including financial institutions and other online services that you link to your account on the Service.
- Public sources, such as social media platforms.
- Business partners, such as joint marketing partners and event co-sponsors.
1.3 Personal Information Collected Automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Service and other sites and online services, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Some of our automatic data collection is facilitated by cookies and similar technologies. See the “Cookies” section below for more information.
1.4 Personal Information About Others. Users of the Service may have the opportunity to refer colleagues or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
2. Use of Personal Information
2.1 To Provide Our Products and Services. For example, we may use your personal information to:
- provide you with information, content, products, features, and services that you have requested;
- establish and maintain your account on the Service;
- process your transactions;
- communicate with you about the Service (including by sending announcements, updates, security alerts, and support and administrative messages);
- facilitate the interactions and communications between clients and advisors;
- display your content or share your information with advisors, other companies, or users;
- understand your interests, personalize your experience on the Service, and deliver information about products and services relevant to your interests; and
- respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.
2.2 For Marketing and Advertising. We, our business partners, and our third-party advertising partners may collect and use your personal information to provide relevant marketing messages to you in connection with your use of our services and for interest-based advertising purposes.
- Direct Marketing. We may send you Income Lab-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
2.3 For Research and Development. We use personal information to understand and analyze the usage trends and preferences of our users and visitors to make our in an effort to better understand our products, services, and business in general, to make our Service and other offerings better, and to develop new features and functionality.
2.4 To Create Anonymous Data. We may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
2.5 Compliance and Protection. We may use your personal information to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
2.6 With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.
3. Disclosure of Personal Information
3.3 Authorities and others. Law enforcement, government authorities, and private parties, if compelled to in connection with a legal or regulatory proceeding, in connection with enforcing our rights or defending ourselves in a legal or regulatory process, as we believe in good faith to be necessary or appropriate to comply with law, or for the other fraud prevention and safety purposes described above.
3.4 Business Transferees. If we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Income Lab or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.5 Advertising Partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
3.6 Business Partners. Our business partners, such as those that have joined our programs, participate in our events, or jointly offer content, promotions and other service offerings with us.
3.8 Other Users and the Public. The Service may provide you with the opportunity to connect with your advisors or clients, or to post or make available content, messages, and other information to other users of the Service or the public. For example, you may be able to post your content in a public forum on the Service or participate in a message board. We do not control how other users or third parties use any personal information that you make available to them.
3.9 Our Professional Advisors. We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
4. Behavioral Advertising Networks
Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Some of the third party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
5. Cookies and Similar Technologies
5.1 What are cookies?
A cookie is a small text file that a website saves on your computer or mobile device when you visit a website or online service. It serves a variety of functions, including enabling the website to remember your actions and preferences (such as login, language, and font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the website or browse from one page to another.
5.3 How to Control Cookies.
Most browsers let you control and/or delete cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, see www.allaboutcookies.org. You can delete cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a website and some services and functionalities may not work.
We use Google Analytics to help us understand user activity and patterns on the Website. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. You can prevent the use of Google Analytics relating to your use of our Website by downloading and installing a browser plugin available here.
5.4 Other Technologies. We may also use the following technologies in connection with the Service:
Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
6. Your Choices
You can make the following choices with respect to your personal information.
6.1 Access or Update your Personal Information. You may request access to your personal information, or request to correct or amend any personal information that is inaccurate or incomplete, by contacting us through the contact information in the “Contact Us” section, below.
6.2 Opt-Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected] You may continue to receive service-related and other non-marketing emails.
6.3 Third Party Services. If you choose to connect to the Service through your account with a third party service, you may be able to use your settings in your account with that service to limit the information we receive from it. If you revoke our ability to access information from a third party service, that choice will not apply to information that we have already received from that third party.
6.4 Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6.5 Declining to Provide Information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
We use reasonable efforts to incorporate commercially reasonable technical, organizational and administrative safeguards to help protect and secure your Personal Data. However, you must understand that no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and your use of the Service and Website is at your own risk.
8. No Use by Children
The Website and Service may be used only by adults who are a United States resident and of sufficient age and otherwise able to enter into a legally binding contract. In no event may the Service be used by a child under the age of 16. If you become aware that a child under the age of 16 has provided us with personal information online, we ask that a parent or guardian please contact us.
9. International Transfers
Wherever you use our Website or access our Service, you understand and acknowledge that we may transfer, process, and store information about you in the United States and other countries (including countries located outside of the jurisdiction where you reside). By providing us with your information, you consent to the transfer of your information to, and to its processing and storage in, countries outside of your country of residence. Those countries may have different data protection laws than those in the country in which you reside.
10. External Links and Third-Party Sites
The Service may contain links to other websites. We are not responsible for the actions or content of these websites or their privacy policies, and do not control them. Linking to a website does not constitute an endorsement by us of, or representation that we are affiliated with, the sponsors of the website or the products presented on the website. If you decide to access any of the third-party websites linked to the Service, you do so entirely at your own risk and subject to the terms and conditions of use and privacy policies for such websites. We encourage you to read the privacy policies of the other websites and online services you use.
12. Contact Us
13. Notice to California Residents
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Company are entitled to ask us once a year for information regarding the personal information we have shared, if any, with third parties for their direct marketing purposes. If you are a California resident and would like to submit such a request, please submit your request in writing to the address listed in the section titled “Contact Us” above and include the words “Shine the Light” in your correspondence. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.
Last Updated: August 3, 2020