Privacy

This Privacy Policy describes the types of personal information that Truelytics Inc. (“Truelytics”) collects through the Truelytics Platform, including this website (the “Website”), how that information is used, and the types of third parties with whom we share it. By using this Website, you agree to be bound by this Privacy Policy, the Terms of Use[1] and all disclaimers and terms and conditions that appear elsewhere on this Website. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU AGREE THAT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE WEBSITE.

This Privacy Policy concerns use of the Truelytics Platform by Subscribers, Advisors, and Authorized Users. Clients or other consumers of a Subscriber and/or Advisor are subject to any privacy policy of the particular Subscriber and/or Advisor. For the avoidance of doubt, use of the terms “you,” “your,” and the like in this Privacy Policy refers to Subscribers, Advisors, or other Authorized Users of the Truelytics Platform.

Please note that this Privacy Policy applies to information Truelytics collects from you via the Truelytics Platform, and information obtained and disclosed through offline correspondence or personal contacts with our customers. Further, the Truelytics Platform may contain advertisements and/or links to other entities’ websites that are not controlled or operated by Truelytics. This Privacy Policy does not apply to such third party websites, and Truelytics is not responsible for the content of such third party websites or the privacy practices of such third parties. Therefore, we encourage you to request and review the privacy policies of any third parties upon disclosing your information such parties or visiting such third party websites.

You agree that we may modify this Privacy Policy at any time. We will have no further obligation to notify you of any modifications. It is your responsibility to review this Privacy Policy from time to time to see if modifications have been made. Any modification is effective immediately upon posting on www.Truelyticsanalytics.com. Your continued use of this Truelytics Platform following modification of this Privacy Policy will be conclusively deemed to signify your acceptance of the modification. Notwithstanding the aforesaid, for any material changes, we will seek your consent to the extent required by law. Truelytics reserves the right, at any time, to modify or discontinue, temporarily or permanently, the Truelytics Platform or any part thereof without notice.

1. Information Collected

We collect information about you in three ways:

Information you provide: When you create an account on the Truelytics Platform (the “Truelytics Account”) or log into the Truelytics Platform, you will have the option of providing Subscriber Information, including personally identifiable information, but not account numbers, about the investment advisor practice (the “Practice”) associated with the Truelytics Account. The Subscriber Information may include information about Advisors and/or Clients of the Practice, including the following: names, addresses, telephone numbers, facsimile numbers, email addresses, dates of birth, Truelytics Account user names and passwords, asset management information, revenue sources, equities, holdings, commodities, and real estate holdings.

Information from Third Parties and other Sources: Third parties may provide us with information about the Practice and Advisors and Clients of the Practice. We may also obtain additional commercially available information from third parties.

Information from Your Use of the Truelytics Platform: We may collect information from you via the Website and other aspects of the Truelytics Platform, including your use of, and activities on, the Truelytics Platform.

The Subscriber Information will be collected according to all applicable Laws, including any notice requirements necessitated under the Laws.

2. Use of Your Personally Identifiable Information

The Subscriber Data, including any personally identifiable information, that you provide and that we collect will be stored and maintained by Truelytics for so long as we, in our sole discretion, believe is necessary or appropriate (a) to carry out the purpose(s) and the use(s) for which such information was collected, or (b) to comply with applicable laws, contracts, or other rules or regulations.

When you contact Truelytics, we may keep a record of your communication to help solve any issues you might be facing.

Upon our collection of the Subscriber Data, Truelytics may use such Subscriber Data, including any personally identifiable information, internally, separately or in combination with pre-existing information, for the purposes set forth below. We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

  • To provide Services to you;
  • To generate Truelytics Processed Data;
  • To contact you, including via email, to respond to your comments or requests for information;
  • To troubleshoot problems with the Truelytics Platform, or any services, as requested;
  • To improve our products and services and identify, develop or offer new products and services;
  • To contact you with more information about Truelytics and its services;
  • To customize your experience, content or homepage on the Truelytics Platform, including providing you with more relevant products, services or content;
  • To enforce the Terms of Use or this Privacy Policy;
  • To generate aggregate statistical studies and conduct research which may be used in marketing our Services to you or to third parties;
  • To offer you products or services offered by Truelytics’s authorized partners; or
  • To provide any legitimate business service or product.

When showing or providing you with tailored content, we will not associate a cookie or anonymous identifier with sensitive categories, such as those based on race, religion, sexual orientation or health.

We may combine personal information about you received from several sources, including without limitation, the information described above for the Subscription Purpose and/or to generate Truelytics Processed Data. As provided in the Terms of Service, we may share the Truelytics Processed Data, in an aggregated non-personally identifiable manner with third parties.

3. Data Sharing and Transfer

Truelytics will not trade, sell or share the Subscriber Information, and the personal identifiable information contained therein, for use by any third party except in the following circumstances:

  • With Authorized Service Providers – You, at your discretion, may elect to purchase from Truelytics one or more third party services to be fulfilled by Truelytics’s authorized partners (each a “Truelytics Partner”).  For each such service that you purchase, Truelytics may disclose the Subscriber Information to the Truelytics Partner for the purposes of providing the applicable service.  Use of a service provided by a Truelytics Partner is subject to such Truelytics Partner’s privacy policies and terms of use for the applicable service.
  • For External Processing – We may provide your personal information to our affiliates or other authorized service providers that provide services to help us with our business activities, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties are authorized to use your personal information only as necessary to provide these services to us.
  • As Required by Law or for the Protection of Rights – Truelytics reserves the right to disclose your personally identifiable information based on the good faith belief that such action is necessary or appropriate to: (a) meet any applicable law, regulation, legal process or enforceable governmental request; (b) enforce the Terms of Use or Privacy Policy, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect and defend the rights or property of Truelytics, or (e) act in urgent circumstances to protect the safety or security of the public or of users of the Truelytics Platform.

In each circumstance, Truelytics will share the Subscriber Information according to any privacy policy the Practice may have with the Clients regarding the sharing of personal identifiable information.

Notwithstanding the aforesaid in this Section 4 above:

  • We may share Truelytics De-Identified Data, publicly and with companies or financial institutions that perform marketing services on our behalf or with other financial institutions with which we have joint marketing arrangements;
  • We may sell such Truelytics De-Identified Data to third parties; and
  • We may combine information collected about you we already have about you, and share it, in an aggregated, non-personally identifiable manner, with third parties.

In the event that Truelytics is involved in a transaction such as a merger, stock purchase, bankruptcy or sale of substantially all of Truelytics’s assets, the Subscriber Information, including any personally identifiable information may be transferred to the other party in such transaction. You will be notified via email and/or a prominent notice through the Truelytics Platform of any change in ownership (other than where the new owners are affiliates of Truelytics) or uses of your personal information, as well as any choices you may have regarding your personal information.

4. Cookies and Other Technologies

We use various technologies to collect and store information when you use the Truelytics Platform, and this may include sending one or more cookies or anonymous identifiers to your device, including “web beacons”, clear GIFs, pixel tags and other means. Cookies help us in many ways to make your use of the Truelytics Platform more enjoyable and meaningful to you. Cookies are text information files that your web browser places on computer and/or your mobile device when you visit a website. Pixel tags are not visible to the user of a website and consist of a few lines of computer coding delivered with the web pages accessed. Truelytics may use such technologies to obtain non-personal information from you as an online visitor. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. You can remove certain cookies by following the directions in your Internet browser’s “help” file. Please note that without cookies, you may not be able to take full advantage of all of the features of the Truelytics Platform.

5. Children’s Privacy

The data products and services provided by the Truelytics Platform are not directed at children and children are not intended as the audience of the Truelytics Platform. Furthermore, neither the Truelytics Platform nor third parties on behalf thereof knowingly collect any personal information from children under 13 years of age. Accordingly, the provisions of the Children’s Online Privacy Protection Act do not apply to the Truelytics Platform. We encourage all parents to talk to their kids about online safety and to monitor their children’s use of the Internet and mobile applications.

6. Access to your Information

We attempt to keep your files complete, up-to-date, and accurate. We tell you how and where to conveniently access your personal information and how to notify us about errors. We offer several ways for you to access and/or update the personal information in the Truelytics Account:

  • You may use the contact information set forth at the end of this document to contact us for any inquiry or request regarding our privacy policy or the handling of your personal information.
  • You may log in to the Truelytics Platform and enter any new information about yourself.
  • You also may write to us directly if you wish to: (a) update or delete your personally identifiable information; (b) close your account; or (c) request that we cease sending you promotional or other information via mail or e-mail. Such written requests should be sent to Truelytics at the address below. We will comply with requests for the deletion of information subject to the provisions of Section 8

We reserve the right to deny access to personally identifiable information in your Truelytics Account (a) when such denial of access is required by law, (b) when granting you access is reasonably likely to negatively impact other people’s privacy, (c) to protect our rights and property, and (d) when such requests are frivolous or made in bad faith.

7. Choice and Opt Out Preference; Termination.

If, at any time, you prefer not to receive further e-mail communications from Truelytics, you will have the ability to unsubscribe from all of some of such communications by updating your preferences in your Truelytics Account or to write to us to opt out in accordance with the contact information below. If, at any time, you prefer not to receive any other form of communication from Truelytics, you will have the ability to unsubscribe from such communications by contacting us at the address below as well as to close your Truelytics Account.

If you wish to cancel your Truelytics Account or request that we no longer use your information to provide you services contact us in accordance with the contact information below.

We will retain your information for as long as your Truelytics Account is active or as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Governing Law and Jurisdiction

The interpretation of this Privacy Policy and all matters arising out of or relating to this Privacy Policy shall be governed according to the Terms of Service.

9. Questions or Comments

The Company welcomes questions and comments about this Privacy Policy, the Terms of Service, and/or our use of your information. Questions or comments should be directed to www.truelytics.com/contact
[1] Capitalized terms not defined in this Privacy Policy are defined in the Terms of Service.