Privacy Policy

PRIVACY NOTICE
Revision Date: 05.25.18

This privacy notice (“Privacy Notice”) sets out the privacy practices of My Financial Services (“Website”). Generally, you may visit the Website without providing personal information about yourself. However, there are times when we may need to obtain personal information from you in order to provide certain services, products, or communications with you. The purpose of this Privacy Notice is to help you understand what information we collect as well as how we use and safeguard the information you provide to us on our Website or through other means of communication with us including our surveys. By interacting with this Website, you agree that your visit to our Website and any dispute over our online privacy practices, is governed by this Privacy Notice.

Personal Information We Collect

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (collectively “Personal Information”), including:

  • Identifiers, which may include your name, physical address, email address, phone number, mobile number or other similar identifiers.
  • Commercial and Customer information, which may include your visiting one of our client’s websites, purchase of products or services from us or third parties, profile information relating to your interests, internet usage, search history, feedback information, communication preferences, customer service and communication history.
  • Internet or other electronic network activity information, which includes your IP address, log data, analytics data, device ID, and other data collected through pixels, cookies, web beacons, JavaScript, and similar technologies on our and third party websites. This may also include your browsing history, search history and your interaction with a website, app, or advertisement.
  • Geolocation data, when we collect your IP address we collect your general geographic location when viewing our website. If you provide your address in response to a prompt, then we collect then we collect your precise geo collection.
  • Audio, electronic, visual, or similar information, where permitted by law, we may record phone calls between us or our customer service providers. We may also implement technology on our website which tracks and captures your browsing and use of Services while on our website.
  • Professional or employment-related information, when verifying your identify, including the business or organization you are employed by or represent, your title with that business or organization, and information relating to their role with the business or organization.
  • Demographic information, which may include your age and date of birth.
  • Inferences drawn from other Personal Information or data, means we use all of the information we and third parties collect from you to draw an inference about interests and preferences you would like us to use based on our and third-party’s analysis of your trends and this may include making a profile of you which includes all information we or they have collected.
  • certain demographic data, when you choose to voluntarily provide to us by subscribing to a newsletter, making inquiries regarding our products or services, requesting news from us, participating in surveys and the results of the surveys, reporting any issues you have found with our Website, participating in a promotional offer, providing us with feedback on our Website, or otherwise interacting with us.
  • We do not knowingly collect, use, or disclose personal information from children under the age of 16. If we find we have collected any information regarding a child, we will immediately delete the same. By using our Website, you represent that you are at least 16 years of age.
  • When we provide you the opportunity to engage in public actions such as comment on articles on the Website that are designed to be visible to other users, including comments, reviews, ratings, or any other items that you submit for publication, then the information disclosed in your public activities, along with your name, image or photo, becomes public and may be used for online and offline promotional or commercial uses in any and all media. If you choose to engage in public actions, you should be aware that any personal information you submit can be read, collected, and used by other users of these areas. We are not responsible for the personally identifiable information you choose to submit in the course of your public actions, and we have no responsibility to publish, take down, remove, or edit any of your public postings or submissions.

How and Where We Collect Personal Information.

Generally, we collect Personal Information directly from you when you visit our Website and provide information when prompted or fill out our registration form or survey or contact us directly. We also collect your information automatically when you visit our Website. We also collect information about you from third-parties, contractors and service providers.

  • Information You Provide To Us. We may collect Personal Information directly from you when you provide it to us through the Websites or Services. This may include the information you provide in response to our request or prompt. We may also receive information from you when you contact us with questions or concerns.
  • Information Automatically Collected. When you visit or interact with the Websites, we may use a variety of technologies such as pixels, cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies or third-party services which automatically or passively collect Personal Information about you and your interactions with Websites. We may also automatically collect the following information about you:
      • Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
      • Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
      • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
      • Analytics. We may also use Google Analytics and other service providers to collect and process analytics information on our Services. We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collect information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.
  • Computer or Device Information: We automatically collect your Internet Protocol ("IP") address or other unique identifier or information from the computer, mobile device, tablet you use to access the Websites, including but not limited to your browser type, device type, system type, and the domain name from which you accessed the Websites.
  • Usage Information: We may collect information about your use of the Websites, including the date and time you visit the Websites, the content, areas or pages of the Websites that you visit, the website or app from which you navigated to the Websites, the page or app you visit after leaving the Websites, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites. For legal compliance purposes, we may also capture or record your interactions with the Website to confirm that your information was submitted to us.
  • Third-party Providers: We use third-party service providers to support our Websites. Some of these service providers may use technology such as pixels, cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.
  • Use of Third-Party Analytics and Technologies: We use various ad services provided by Google that connects the activity on our Website with their advertising network and they may use cookies that collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google’s Analytics Advertising. This includes: (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) Google controlled Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-on here https://tools.google.com/dlpage/gaoptout/.
  • Information from Third-Party Websites or Services: If you link to us through a third-party website, email, or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to, your name, username, demographic information, updated address or contact information, location, interests, and online activity.

Information Collected From Third Party Sources. We may acquire Personal Information from other sources as follows:

  • Service Providers: We use third-party service providers to support our Websites and Services and business processes including without limitation, identifiers, internet and electronic network activity, general geo location, and inferences.
  • Third-parties: We obtain Personal Information about you from third-party sources, including commercially available sources, data aggregators and public databases as well as companies that license or sell your information to us. This information may include your name, general geographic information, IP Address, and publicly-observed data.
  • Combining Information. We may combine the Personal Information we receive from you, Third Parties and information we automatically collect through the Websites and/or Services, as well as information collected from other online or offline sources, including from third-party sources. This will provide us with a profile of you which we may be able to use for provision of our services to you as well as identify other products and services that may interest you.

How We Use Your Information

  • We collect, retain and use information you provide us for to: correspond with you regarding our Website or services; inform you of developments in our company or with our services that we believe may be of interest to you; We may customize your use of the Website’s services; send you newsletters or news alerts; monitor Website traffic patterns and Website usage; comply with applicable laws; enforce our Terms of Use or other agreements; maintain or administer the services, perform business analyses or for other internal purposes to improve the quality of our business, the Website and other products and services we offer; and protect the rights, property or safety of the Website, our users and others.
  • The information, including the personal information, you provide to us may be used for any purpose we deem appropriate and may be given or disclosed to our affiliates, partners, vendors, advertisers, licensees, and third parties. You acknowledge that you understand when you disclose personal information (name, email address, zip code) in connection with your use of our services, such information can be monitored, collected, and used by us or others and may result in unsolicited messages from other users or third parties.
  • We may use demographic and preference information to provide advertising on the Website to target the users for whom they are most pertinent. This means users may see advertising that is most likely to interest them, and many advertisers send their messages to people who are most likely to be receptive, improving both your experience and the effectiveness of the advertising.
  • We may use your information to show you relevant ads both on our services and elsewhere or measure the effectiveness of ads. To learn more about how you can opt out of interest-based advertising, please visit www.networkadvertising.org.

How We Disclose Your Information

  • We may disclose, share, and sell your Personal Information as described below.
  • Third-party Product and Service Providers. We disclose, share, and sell your Personal Information to third-party product and service providers to provide you with the products and services you have requested through your registration on our Website and Services.
  • Parent and Affiliated Companies. We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.
  • Service Providers. We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.
  • Sale or Transfer of Business or Assets. We may disclose, share, and sell your Personal Information as part of our sale of assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. If we file for bankruptcy or reorganization information we have collected about you may be considered our asset and may be included in the assets transferred.
  • Marketing Vendors and Other Third-parties. We may disclose, share, or sell your information to third-parties who provide display and/or email services or other third-party vendors we use who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for our and third-parties use on and to manage and improve our advertising campaigns.
  • Compliance with Laws. We may disclose your Personal Information to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclose and share your Personal Information to third-parties to assist us in compliance with Laws.
  • Enforcing Our Rights. We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes, with clients, third party service provides and other third-parties or contractors who provide you with the product or service which you have requested or to protect the security of our Websites, servers, network systems, and databases and enforce our contractual rights with these parties..
  • Acquisition or Merger. We may disclose, share, sell and otherwise transfer your Personal Information to a third-party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of our assets.
  • Aggregate or Anonymous Non-Personal Information. We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.We may provide your information, including your personal information, to third parties, such as service providers, vendors, and advertisers, for a variety of purposes, including, without limitation, for direct marketing purposes. We reserve the right to disclose to third parties all of the information that we collect online about you and other visitors.
  • We may share in aggregate, statistical from non-personal information regarding the visitors to our Website, traffic patterns and Website usage with our affiliates, investors, advertisers, or other third parties.
  • We may disclose information we maintain when required to do so by law or may disclose such information in response to a request from a law enforcement agency or authority, subpoena, court order or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • We may share information with third parties in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use or as otherwise required by law.
  • If we sell, buy, or merge with other companies or businesses. In such transactions, we may include your information among the transferred assets.
  • We share your information with third party advertising companies to target and serve some of the advertisements that appear on our Website, and these companies likewise may use their own cookies, web beacons and similar technologies to collect information from users of our Website. These companies may use that information, sometimes in conjunction with similar information gathered from other websites, to deliver advertisements on this Website, tailored to match the interests of consumers. The collection and use of information by these companies is governed by the relevant third party’s Privacy Notice and is not covered by our Privacy Notice. If you would like information on how to opt-out of these information collection practices, please visit http://www.networkadvertising.org/choices/.

Links to Third Party Websites

Our Website may offer links to other websites, including links embedded in advertisements and links to various news sources that are not under our control. Such links to other websites may have information policies and practices different from ours. We do not own or control such companies and websites and are not responsible for the privacy policies or practices or the content of such websites.

How We Protect Your Information

We use reasonable industry-accepted technology and controls to protect your data from disclosure to unauthorized third parties. Although these measures have been found by our industry to be effective, use of the Internet and computer systems remain vulnerable to unauthorized access. Thus, we do not guarantee that all information you provide to us will not be accessed by unauthorized persons. We are not responsible for third party conduct outside of our control.

Changes to This Privacy Notice

This Privacy Notice may be changed from time to time. Any changes will be posted on this page. Any revised Privacy Notice will apply only to information collected after the effective date of such revised Privacy Notice, and not to information collected under any earlier Privacy Notice.

Opting Out

If, at any time, you prefer not to receive email marketing information, surveys, or newsletters from us, simply follow the unsubscribe link at the bottom of each email or email us at [email protected].

California Resident rights.

Shine the Light: One time a California resident can ask us to disclose what information we received or shared about them and from what category of third-parties this was done for marketing purposes. California residents also have the right to know we do not respond to do not track signals or cookies. Please make this request by calling us Toll Free at 866-245-9626. .

California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020:

This portion of our Privacy Notice is for California Residents Only and supplements the information contained in our general Privacy Notice. This notice is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice. The Purpose of this Notice is to provide you with a description of our practices regarding the collection, use, disclosure, and Sale of your Personal Information and how to review, correct or delete your information.

California Resident Privacy Rights.

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of Personal Information (as defined in the Shine the Light law) to third-parties for their direct marketing purposes. To opt-out of this type of disclosure, please call us Toll Free at 866-245-9626. .

B. California Consumer Privacy Act of 2018. This Privacy Notice for California Residents supplements the information contained in our primary Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and CPRA have the same meaning when used in this Notice. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

C. Additional Personal Information Disclosures

  • Additional Disclosures on Sales, Sharing, or Targeted Advertising. As further described in the Privacy Notice, we may “sell” or “share” your Personal Information (as those terms are defined by the CCPA to third-parties, subject to your right to opt-out of those sales. In the last 24 months, we sold, shared (for cross-context behavioral or targeted advertising purposes), or disclosed the Personal Information (for the purposes described in our Privacy Notice) as follows:
    • Third-party Business (clients) and Marketing Companies: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
    • Online Advertising Networks, Social Networks, and Analytics Providers: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
    We also disclose Personal Information to third-parties at your direction or upon your request, in connection with a service or product you have requested or received; for our corporate business transaction; or to comply with legal or contractual obligations; as described in our Privacy Notice. In the last 12 months, we may have disclosed each category of Personal Information for these purposes. De-identified Information. We may receive or process Personal Information to create, de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law.

 

D. California Privacy Choices. If you are a resident of California, and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  • RIGHT TO KNOW. The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
    • The categories of Personal Information collected;
    • The categories of sources of the Personal Information;
    • The purposes for which we collected the Personal Information;
    • The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;
    • The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
    • The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.
     
  • RIGHT TO CORRECT. The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information, and the purposes of processing the Personal Information.
  • RIGHT TO DELETE. The right to have us delete the Personal Information we maintain about you, subject to additional exemptions.
  • RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION. The right to exercise control over our collection and processing of Sensitive Personal Information.
  • RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION The right to direct us not to “sell” your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share and sell your Personal Information to the third parties who provide to you the services and products you requested at registration.
  • RIGHT TO PORTABILITY. The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • RIGHT AGAINST DISCRIMINATION OR RETALIATION. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
  • OPT-OUT PREFERENCE SIGNAL (GLOBAL PRIVACY CONTROL). You may use an Opt-Out Preference Signal, such as the Global Privacy Control (GPC), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request.
  • HOW TO EXERCISE YOUR RIGHTS. Submit your request to exercise one of the privacy rights identified above, as follows:
      • Submit your request using our online form; or
      • Call us Toll Free at 866-245-9626.
     

Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. As a result, we require requests to include first and last name, phone number, email, street address, city, state, and zip code. We may at times need to request additional Personal Information from you, taking into consideration our relationship with you and the sensitivity of your request.

We will process requests to opt-out of sales within 10 business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within 45 days, subject to any applicable exceptions and extensions permitted by law.

In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of California, or where we are unable to verify your identity.

E. Submitting Authorized Agent Requests. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you or the California Resident to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

F. Retention of Personal Information. We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. As such, we retain Personal Information for as long as you continue to use our Websites and/or services for the purposes explained in our Privacy Notice. When you discontinue the use of our Websites or services, we will retain your Personal Information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices you have made, such as to receive marketing communications. In particular, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims. Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.