Policy Effective Date: January 25, 2016
Your Privacy Matters
Finhabits’ 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.
Information Collection 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 also collect your email address and/or telephone number should you opt to engage via our web-based application, email or dedicated telephone number with our client service team.
Information Collection from Clients
If you choose to become a Client, in addition to the information we collect from you as a User, as described above, we will ask you for certain information, including, but not limited to, your full legal name, contact information, birth date, Social Security Number, citizenship, investment objectives, approximate net worth, and other regulatory disclosures that may be necessary and required under Federal and certain statutory law (see our Client Agreement).
We also collect 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.
FinHabits’ servers automatically record certain information (“Non-Identifiable” or “Aggregated Data”) about your use or evaluation of our Service. Similar to other technology platforms and services, FinHabits records information such as browsing activity, data displayed or clicked on (such as UI elements, ads, and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, FinHabits may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the website.
Use of Information
FinHabits stores, processes, and maintains data 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. 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.
We may share the information required to become a Client with our brokerage partner solely for the purpose of allowing our brokerage partner to provide services to you.
FinHabits may use your Personal Data 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 marketing communications from us, please follow the “unsubscribe” instructions provided in the communications. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.
Information Sharing and Onward Transfer
There are certain circumstances, outlined below, in which we may share your Personal Data without further disclosure to you. From time-to-time, we hire other companies to perform certain business and technology related functions (e.g. mailing information, database maintenance and payment processing). In the case we hire another company to perform a function of this kind, we only provide them with the minimum information they need to perform their specific function. FinHabits maintains strict physical, electronic and procedural safeguards that comply with federal standards to guard your Non-Public personal information.
Except as required by law or requested by regulatory authorities, FinHabits agrees to maintain your non-public Personal Data in strict confidence.
Your Choices and Obligations
You may request deletion of personal information by emailing firstname.lastname@example.org and providing us enough information to identify your account and prove that you are the owner of the identified account. We will endeavor to make any deletion request effective as soon as reasonably practicable. 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.
You may decline to provide personal information to FinHabits. Declining to provide personal information may disqualify you for FinHabits services and website features that require certain personal information.
Other Important Information
FinHabits takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free so, please take special care in deciding what information you send to us in this manner.
We do not allow third party advertising on our Website or Mobile applications.
FinHabits manages a referral program called “The FinHabits 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 email address. We treat this information like all our other Personal Data.
Social Media and Links to Other Web Sites and Apps: “Third Parties”
FinHabits is not to be used by anyone under the age of 18 and, as such does not knowingly collect Personal Data from anyone under the age of 18. If you are under the age of 18, please do not submit any Personal Data to FinHabits. If a parent or guardian becomes aware that his or her child under the age of 18 has provided us with personally identifiable information without his or her consent, he or she should contact us at support@FinHabits.com and we will delete such information from our files.
Finhabits Advisors LLC
154 Grand StNew York, NY 10013