2. How and when we collect information
We collect information in the following ways:
- Anonymous information that we collect from users who browse the Sites (section 2.1);
- Information you provide to us when you register to attend any of our events, respond to surveys, or contact us for more information about Vestwell’s services (section 2.2);
- Information you provide to us when you register for an account to use or market the Vestwell Platform, when you contact us for technical or other support services, and in other instances as discussed more below (section 2.3).
2.1 Anonymous information we collect from users of our Sites
A user can browse through our Website(s) without providing us with any personally identifiable information. However, certain information may be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, unique identifiers, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream).
Device and location information: We collect device-specific information, such as whether you are accessing the Sites from a mobile phone or laptop, the website URL that directed you to our Sites, the Internet Protocol address, the browser version of your device, the date and time of your access to the Sites, and the pages or screens that you accessed while at the Sites.
2.2 Information you provide to us
In addition, Vestwell collects and uses the personal information that a user proactively provides to us. When you register for one of our webinars, seminars, or online programs or events; respond to any surveys, emails, sponsored content on LinkedIn or other social media sites, or questionnaires; or if you contact us to request information or correspond with us. In those instances, you may be requested to provide your name, address, company, and contact information. We use that information to keep in contact with you to inform you about Vestwell’s services, product enhancements, and related educational and promotional materials.
2.3 Information you provide to us when registering for an account
Plan sponsors, advisors, and participants who use the Vestwell Platform to manage their retirement plan or retirement plan account consent to provide Vestwell with information needed to service the plan or the account. That information includes name, address, salary, years of service, job position, contributions, investment options, and investment performance. That information is used by Vestwell and our service providers and business partners to perform the services specified in the Vestwell Plan Services Agreement between Vestwell and the plan sponsor.
3. How we use information collected
Vestwell uses the information we collect for our own general business purposes, which may include, but not be limited to: helping us analyze, research, report on, and improve upon the services we provide; understanding and resolving the root cause of any technical issues with the Sites or servicing your account; better serving our current and prospective client and advisor needs with respect to our products, services, and support; marketing our services or the services of our third party business partners, to you; and keeping you up to date on updates, industry information, and offers. You may opt out of receiving these marketing communications at any time (see “Choice/Opt-Out” below).
In addition to cookies, our Sites use a variety of other methods and tools for tracking purposes, including Internet tags and web beacons, which are small pieces of data that are embedded in images and pages of our Websites. While most web browsers automatically accept cookies, many browsers allow you to modify your browser setting to decline cookies and/or “opt-out” of tracking technologies. Please note however, if a visitor turns off cookies, such visitor may find some of the functionality of our Sites and/or our services and apps to be reduced or impaired.
We also utilize both proprietary and third party analytics tools, such as Google Analytics, to gather information designed to help us gain insight into how visitors interact with and use our Websites and Services. You can prevent your data from being collected by Google Analytics on our Sites by installing the Google Analytics opt-out browser add-on, which is available at https://tools.google.com/dlpages/gaoptout.
5. Information sharing and disclosure
If you enter a contract for services with Vestwell, we need to transfer a plan sponsor’s and participant’s personal information within Vestwell or to Vestwell’s third party service providers in accordance with such contract for services. In addition, Vestwell may send personal information about our plan sponsors or participants using the Vestwell Platform to other companies or people under any of the following circumstances: (i) when we have your consent to share the information; (ii) we need to share your information to provide the service you have requested; (iii) we need to send the information to companies who work on behalf of Vestwell to provide a service to you (we will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose); or (iv) we want to keep you up to date on announcements, updates, or other information we think you’d like to hear about either from us or from our business partners (unless you have opted out of these types of communications).
On Sites where your personal information is subject to opt-in, unless you opt-in, Vestwell will not transfer such personal information to third parties, except we may transfer your personal information without your consent to the extent required to do so by law or in the good faith belief that such action is necessary to: (i) conform to the edicts of law or comply with legal process served on Vestwell or the site; (ii) protect or defend the rights or property of Vestwell; (iii) act in urgent circumstances to protect the personal safety, property, or privacy of Vestwell’s employees, users of Vestwell’s products or service, or members of the public; or (iv) effect a transaction, restructuring or proceeding that transfers to a third party the assets or line of business to which the information pertains.
In addition, we may share non-identifiable aggregate information about our users (for example, the proportion of male and female users) with advertisers, business partners, and other third parties in an effort to customize or enhance the content and advertising on our Websites for our users.
6. Information security
Your privacy matters to Vestwell and we work hard to protect it. We strive to use industry best practices to protect users of our services from unauthorized access, alteration, disclosure, or destruction from information we hold about our plan sponsors and plan participants. We utilize the following practices:
- We encrypt data on the Vestwell Platform;
- We enforce password complexity standards for individuals to access their accounts on the Vestwell Platform;
- We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems; and
- We restrict access to personal information to Vestwell employees and trusted service providers who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
7. It’s your choice, you can opt out or review information
With respect to all other information that you proactively provide to us, such as when you attend one of our educational events or register for an account, unless you take affirmative action to “opt-out,” we assume that you have given us your consent to collect and use your information in accordance with this Policy. The “opt-out” checkbox is the means by which you give us, or decline to give us, your consent to use your personal information for the purpose(s) covered by the applicable opt-out choice. You may indicate your desire to “opt-out”: (i) at the point of data collection when your personal information is entered by using the “opt-out” checkbox, (ii) when you receive marketing and promotional communications from us by clicking the “unsubscribe” hyperlink and following the instructions, or (iii) at any time by sending an email request to support@Vestwell.com (please indicate “Opt-Out” in the subject line) or by sending a written request to our address as provided below (“Contact Us”).
In certain cases, we will provide you with the opportunity to “opt-in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted. You may also stop the collection of personally identifiable information in connection with your use of our Services by stopping your use of them.
8. Your Ability to Review and Delete Information
Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it, unless we have to keep that information for legitimate business or legal purposes. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. If you wish to exercise this right, please contact us (see below).
9. Our internal data security protocols
Your personal information is protected for your privacy and security. Vestwell safeguards the security and confidentiality of the data you send us with physical, technical, and managerial procedures. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, take advantage of multi-factor authentication features where available, and make sure you use an up-to-date and secure browser. Don’t store passwords in your browser.
10. Third party service providers or business partners
Vestwell reviews and may amend this policy from time to time. If we make any substantial changes in the way we use your personal information, we will make that information available by posting a notice on this sites.
12. International use statement
13. Contact us
Your privacy matters to us. Vestwell welcomes your comments regarding this privacy statement and our privacy practices. If you have reason to believe that Vestwell has not adhered to this privacy statement, please contact us by email at firstname.lastname@example.org or at Vestwell Holdings, Inc., Legal Department, 22 West 38th Street, New York, NY 10018.
Version 1.0 August 2016
Version 2.0 April 2018