This Privacy Policy is based on the principle that data belongs to its owner, and ownership of data is not altered by storing it in the WealthDrive Platform. Your clients are your clients, and the data that you store in the WealthDrive Platform belongs to you, unless you do not own your client data, and your control and use of your clients’ data is a right/privilege granted to you under a separate agreement with your employer, and that employer is the owner of this data. In this situation, the ownership of data is still not altered by entering it onto the WealthDrive Platform.

We utilize the data in your individual account to assist you with support requests, troubleshoot problems, or monitor the performance and effectiveness of the system. In addition, we utilize aggregated data across the WealthDrive Platform to improve its effectiveness, develop insights, general marketing or monitor the performance and effectiveness of the system.

We may collect the following types of information:

Information You Provide

When you establish an account with WealthDrive, we ask you for personal information. We use the data you enter to provide the Services to you. We also analyze all of our customer data in aggregate to understand more about the average WealthDrive user.

Client Information

When you use our Platform, we collect the following information about your clients:

We collect personal identifiers of clients including name and estimated age in order to enable the platform to function.

Clients can also voluntarily submit additional personal information to enhance the functionality of the platform. The category of personal identifiers includes, by way or example, but is not limited to: date of birth, age, gender, phone number, email, address, and information about financial instruments such as account name, location and estimated amount.

Advisor Information

To establish your subscription, you will be asked to provide your first name, last name, address email address, phone number, and credit card information with our credit card processor, which data we will never share with or sell to third parties.

Communications

Any messages, email or communications that you send to us may be retained so that we can process your inquiries, respond to your requests or improve the quality of our services. We may use your email address and other personal contact information to communicate with you about our services.

Cookies

When you visit www.WealthDrive.com and/or the Platform, we send one or more cookies to your computer or other device. We use cookies to improve the quality of our services, store user preferences and track user trends.

Below is a detailed list of the cookies we use on our website and Platform. The specific names and identifiers listed below may change over time. Any cookies with names or identifiers not listed below that perform the same essential function as those listed below will be treated in the same way as the cookies listed below. We classify cookies in the following categories:

Strictly Necessary Cookies

These cookies are necessary for the website and Platform to function and cannot be switched off in our systems. They are usually only set in response to user-initiated requests for services, such as logging in, filling in forms, accessing secure areas of the website, or setting privacy preferences.

• csrftoken: Required data for any POST to be accepted by the application.
• sessionid: Holds unique ID that associates the user with ephemeral storage on the server used by the application.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can improve the performance of the site. They help us know which pages are most and least popular and see how visitors move around the website and Platform. All information these cookies collect is aggregated and anonymous.

• _ga: Set by Google Analytics for anonymized site analytics.
• _gat: Set by Google Analytics for anonymized site analytics.
• _gid: Set by Google Analytics for anonymized site analytics.

Functional Cookies

These cookies allow the provision of enhanced functionality and personalization, allowing the website to remember choices you make or provide services you have asked for. They may be set by WealthDrive or by third-party providers whose services we have added to the pages. Without these cookies, some or all of these functionalities may not work properly.

• wealthdrive-authenticated: Used to determine visibility of “session expired” banner on login page.
• wealthdrive-banner-notify: Value allows suppression of subscription warning banners within a session.
• wealthdrive-env: Records instance that user authenticated against.
• wealthdrive last-seen: Used to determine visibility of “session expired” banner on login page.
• username: Set by the application framework but not used by the application.

Targeting Cookies

These cookies are by advertisers or by WealthDrive to build audience segments and help customize content and messaging for newsletters and landing pages and other user experiences associated with the website and Platform.

• intercom-session-*: Used by customer service to associate users with their support account and allows users to chat directly with CSS team.

The website and Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information about your online activities over time and across different websites or online services. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use the website and how you use the website. We use the information provided by Google Analytics to improve the website. For more information regarding how Google collects, uses and shares your information and how to opt out of certain uses, please visit http://www.google.com/policies/privacy/partners/. By using the website, you consent to the processing of data about you by Google as described here and in Google’s privacy policy.

Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. Please be aware that by disabling cookies some website functionality may be impaired. Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

You can also learn more about online advertising cookies and your ability to opt-out of certain online advertising cookies by visiting the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. For your mobile device, you can understand which third parties have currently enabled cookies on your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website at http://www.networkadvertising.org/mobile-choices from your mobile device. On your mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, though such advertising may not be based on your interests and preferences.

This website does not respond to “Do Not Track” signals.

Log Information

When you access WealthDrive Platform, our servers automatically record certain information in an industry-standard way. These logs may include information such as your IP address, web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. We use logs to improve the quality of our services, debug problems, and track user trends.

This Privacy Policy applies to WealthDrive services only. We do not have any control over the websites offered by our partners, or sites that integrate with WealthDrive services. Those sites are governed by their own privacy policies, which you should read before using them. WealthDrive processes personal information on our servers in the United States of America, and may do so in other countries. In some cases, we may process personal information outside your own country.

WealthDrive only shares personal information with other companies or individuals outside of our company in the following limited circumstances: (1) We have your consent. We require opt-in consent for the sharing of any confidential personal information. This consent can include, but is not limited to, when you choose to integrate WealthDrive services with other third party software or services.

(2) You are an enterprise customer or partner, have contributed confidential data to the WealthDrive Platform and have provided a mapping of your advisor’s rep codes or other identifiers to their email addresses. In that case, we will only share that advisor’s confidential data with their own WealthDrive account.

(3) We may provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons, solely for the purpose of processing that information on our behalf.

(4) We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms and Conditions, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of WealthDrive, its users or the public as required or permitted by law. If WealthDrive is ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

If WealthDrive becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all personal information you provide to us via our interactions.

We restrict access to personal information to only authorized WealthDrive employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

We believe that your data belongs to you, and therefore, you may delete your account at any time that you choose. To request that your account be deleted, please contact us at support@WealthDrive.com. Because of the way we maintain our services to protect the integrity of your data, residual copies may take a period of time before they are deleted, and your data may remain in our backup systems. However, our systems are architected so that your data will drop out of active use for all of the uses that we described above. Confirmation of deletion can be provided upon request.

This section of our Privacy Policy provides certain required information to persons located in the European Union (“EU”), a European Economic Area (“EAA”) member state, or Switzerland. Before WealthDrive collects any Personal Information, as defined by the General Data Protection Regulation (“GDPR”), you are entitled to the information in this section of our Privacy Policy as required by the GDPR.

WealthDrive will only process your Personal Information when WealthDrive has a lawful basis for doing so. WealthDrive will collect and process your Personal Information as necessary for the performance of a contract to which you are a party or because WealthDrive has another legitimate interest in doing so relating to WealthDrive’s business purposes arising from your relationship with WealthDrive. WealthDrive may also seek your prior consent or rely on some other lawful basis to process your Personal Information.

If you use our sites and are located in the EU, EAA, or Switzerland, you are entitled by law to access, correct, amend, or delete Personal Information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

• The right to access. You have the right to ask us for copies of your Personal Information. When making a request, please provide an accurate description of the Personal Information to which you want access. We may charge a reasonable fee based on administrative cost.
• The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• The right to erasure. You have the right to ask us to erase your Personal Information in certain circumstances, including your Personal Information must be erased to comply with a legal obligation under EU or member state law.
• The right to restrict processing. You have the right to ask us to restrict the processing of your Personal Information in certain circumstances, including: (i) when the accuracy of the Personal Information is brought into question, or (ii) when we no longer need the Personal Information for the purposes of the processing but you require such Personal Information for the establishment, exercise, or defense of a legal claim.
• The right to data portability. You have the right to ask that we transfer the Personal Information you gave us from one organization to another, or give it to you.
• The right to lodge a complaint with the supervisory authority. If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
• The right to withdraw consent. If WealthDrive obtains your written consent to collect and process your Personal Information, you can subsequently withdraw such consent as to any further processing of information by contacting us.
• Automated decision-making. To the extent that WealthDrive engages in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

To exercise these rights please contact us at support@WealthDrive.com. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.

You have the right to object to the processing of your Personal Information that is based on legitimate interests. If you make such an objection, we will cease to process the Personal Information unless we can demonstrate compelling legitimate grounds for the processing which override your interests or which override your rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your Personal Information by contacting us at support@WealthDrive.com.

Personal Information that you provide while in the EU, an EAA member state, or Switzerland maybe transferred to the United States. The GDPR permits such transfer when necessary for the performance of a contract between you and WealthDrive, if WealthDrive obtains your explicit consent to such transfer, or if it is WealthDrive’s legitimate interest to transfer the Personal Information. The laws in the United States may not be as protective of your privacy as those in your location. If we transfer Personal Information from the EU, we will provide an appropriate safeguard such as binding corporate rules, standard data protection clauses, or your consent.

We will retain your Personal Information until the Personal Information is no longer necessary to accomplish the purpose for which it was provided. We may retain your Personal Information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

Please note that this Privacy Policy may change from time to time. We will not materially reduce your rights under this Privacy Policy without your explicit consent. We will post any Privacy Policy changes at https://www.wealthdrive.com/security and, if we judge the changes to be significant, we will provide an email notification of Privacy Policy changes.

If you have any questions about our Privacy Policy, please contact us at support@WealthDrive.com.