Privacy Policy

The Wealth Pool

Privacy Policy

Last Revised: November 23, 2020

Your privacy is important to us. The Wealth Pool, LLC and its affiliates (“The Wealth Pool,” “we,” or “us”), understand your concerns with regard to how information about you (“you”) is used and shared, and we appreciate your trust that we will use and share information about you carefully and sensibly. This Privacy Policy describes what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it. This Privacy Policy applies to your use of our Web site and our software application (collectively, the “Site”) and any other means by which we may collect information about you, including information you may provide to us other than on the Site, and information that identifies you (such as your name or email address) or data that could be used to indirectly identify you (collectively, “Personal Information”). We encourage you to become familiar with this Privacy Policy.  By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

This Privacy Policy does not apply to any other websites. We are not responsible for the privacy practices of other companies or other websites. We encourage you to seek out and read the privacy policy of each website that you visit.

1. What information do we collect, and how do we collect it?

We and our third-party service providers (“Contractors”) may collect certain information from or about you in connection with your use of, or your submissions to or via, the Site. The information we may collect  includes, but is not limited to:

• First and last name
• Title
• Email address
• Postal zip code
• Company
• Gender
• Age/date of birth
• Income level
• Education level and institutions attended
• Financial information
• Desired emergency cash reserve
• IRS filing status
• Retirement contribution percentage
• Retirement split percentage
• Employer retirement contribution match percentage
• Rewards payment method email

For example, some areas of the Site may include registration forms that require users to provide some or all of the foregoing information.  In addition, we and our Contractors may retain the content of, and metadata regarding, any correspondence you may have with us or our representatives, regardless of the mode of communication by which such correspondence was made. This information helps us to improve the Site and the online content, materials, and services that we make available on the Site, and to more effectively and efficiently respond to both current and future inquiries.

We and our Contractors may collect Personal Information about you automatically from your browsing on the Site, through the use of electronic tracking processes.  Such information may include but not be limited to the Internet protocol address assigned to your computer, your domain name and host for Internet access, information about your computer’s operating system and browser, the specific pages that you accessed on the Site or prior to or after visiting the Site, and the length of time you spent at the Site. We and our Contractors may use this information to help administer the Site and the servers that provide the Site, generate statistical information, monitor and analyze Site traffic and usage patterns, and improve the Site’s content and content delivery, including any online content, materials, and services that we describe or make available on the Site.

The Wealth Pool uses ENVESTNET | Yodlee  (“Yodlee”) to gather your data from financial institutions. By using our service, you grant The Wealth Pool and Yodlee the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Yodlee in accordance with the Yodlee Privacy Policy.

2. How will we use the information you provide to us?

We use the information that we collect and obtain to conduct our business and to provide you with the Site and the products, services, and experiences that you request or that we think may be of interest to you. In particular, we and our Contractors may use information that you provide to us: (i) to provide you with products and services; (ii) to maintain and service your account; (iii) to process and remit payments; (iv) to administer the Pool Rewards Program and other programs, offers, and promotions; (v) to respond to and communicate with you; (vi) to market and promote our products and services, or the products and services of third parties; and (vii) for other business and legal purposes as we deem appropriate or as may otherwise be permitted or required by applicable law.

In addition to the uses described above or elsewhere in this Privacy Policy, we and our Contractors may use Personal Information to analyze and improve the content, materials, and services that we make available on the Site, to notify you of changes made to the Site, to evaluate user needs and improve the Site content, to send you promotional materials, and support our continuing efforts to offer users the information and services we think they want most. We may use Personal Information from registration forms on the Site to send you information related to our business and services.  If you contact us for support or assistance, we may use Personal Information to provide service and support to you. We may also use Personal Information and the associated statistical data we and our Contractors generate to deliver targeted, personalized advertisements to you and other visitors of our Site.

3. With whom do we share the information we collect?

We do not sell, trade, or transfer your Personal Information to third parties, except in the circumstances described below.

As part our business mission, we share, or in the future will share, financial and demographic information of or about certain users of our Site, on an aggregated and de-identified basis, with users of our Site. 

In addition, we may share Personal Information with certain of our Contractors (e.g., our web hosting provider) in order to provide the Site to you. We and our Contractors may also produce reports on Site traffic, usage patterns, and similar data generated from Personal Information, and we may share these reports with our business and marketing partners and others.

We may share your Personal Information, or information and data derived from your Personal Information, with a third party so that the third party can market its products and services to you. Advertisements may be delivered to you in the form of targeted, personalized ads and/or as “paid attention” ads.

We disclose Personal Information to advertisers, merchants, consumer and market research companies, service providers who help us provide services, or to other third-party service providers who provide certain specialized services to us, to provide services on our behalf, or who co-operate with us on projects. These business partners operate as separate controllers, and are responsible for their own compliance with data protection laws. 

We may disclose Personal Information (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that The Wealth Pool is subject to  mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, Personal Information may be shared, sold, or transferred, and it may be used subsequently by a third party.

We may disclose aggregated, de-identified information, and analyses and reports derived from such information to third parties including utilities, service providers, advertisers, merchants, consumer and market research companies and other organizations.

4. What choices do you have?

We offer certain choices about how we communicate with you and what Personal Information we obtain about you and share with others.

Correspondence and Profile

When corresponding with The Wealth Pool or our representatives, or when making a request for information or otherwise interacting with us or others through the Site, you choose what information to supply, what questions or comments to submit, whether you wish to receive further information, and by what method of communication such information should be delivered. Please take care to share only such information as is needed or that you believe is appropriate. You are under no obligation to provide us with personally identifiable information, but without it we may not be able to provide you the products or services you request. You may contact us as indicated below if at any time you would like to ask us about our data collection and information security practices.

Cookies

Our Site may send one or more “cookies” to your computer that store user preferences and track user trends (also deemed “Personal Information” hereunder). These cookies are placed on your computer when your web browser accesses the Site. We use this information to improve the utility of the Site, and to help us understand things such as how you navigate to and around websites, site browsing and content accessing.

We use third-party services for analytics and interest-based advertising purposes. These service providers and ad partners may use cookies alone or in conjunction with unique identifiers, beacons, and other tracking technologies to collect information about you when you use our website, open our emails, or interact with our ads. We do not combine the information collected through the use of these services with information that directly identifies you.

Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. Please note that by disabling or deleting cookies, you may not be able to access the full functionality of our Site.  Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set.

Do Not Track

Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them at this time.

5. How Do We Protect Information Collected About You?

The Wealth Pool has implemented reasonable physical, technical, and administrative security standards to protect Personal Information from loss, misuse, alteration, or destruction. We strive to protect your Personal Information against unauthorized access, use or disclosure, using security technologies and procedures, such as encryption and limited access. Only authorized individuals access your Personal Information. For further information about our security standards, please click HERE.

6. Interactive Areas

We may provide areas within the Site that allow users to post commentary and other materials. If we do, these interactive areas, such as discussion forums, are intended to enhance the user experience and build a healthy community around the products and services available through the Site. The Wealth Pool is not liable for information posted in interactive areas of the Site. You acknowledge that, should you participate in such interactive areas, the information you voluntarily post about yourself and third parties in such areas might be accessed, collected and used by third parties other than The Wealth Pool or our Contractors.

7. Third-Party Sites.

Occasionally, at our discretion, we may include or offer third-party products or services on our Site. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We urge you to read the privacy policies of other websites before submitting any information to those websites.

8. Do We Transfer Your Personal Information Across Geographies?

This Site is operated from and hosted on servers located in the United States.  However, we and our Contractors may, in our effort to provide the Site, store Personal Information in the United States, or we may transfer it to, and store it within, other countries. If you access and use our Site from a location outside of the United States, any Personal Information you provide to us or that is otherwise collected may be transferred to and processed in the United States or other jurisdictions. Please note that the level of legal protection provided in the United States from which you may access the Site may not be as stringent as that under privacy standards or the privacy laws of other countries, possibly including your home jurisdiction. Visitors from jurisdictions outside the United States visit us at their own choice and risk.

9. Retention of Information

In general, we will keep your Personal Information only for the period necessary to fulfil the purposes for which your information was originally collected. If your account has been inactive or your subscription with us has expired for a period of more than ninety (90) days, then we may delete your account and all associated data. In addition, inactive or stale data may be deleted on an ongoing basis in accordance with our internal data retention policies (currently, once every ninety (90) days). We will not be liable to you or any other person for any deletion or removal of data made in accordance with this Privacy Policy.

10. California Privacy Notice

Pursuant to applicable California law, including the California Consumer Privacy Act (“CCPA”), The Wealth Pool makes the following disclosures regarding the Personal Information we collect:

We have not sold consumers’ Personal Information in the twelve (12) months preceding the effective date of this Privacy Policy.

If you are a California resident, pursuant to the CCPA, you have the right to request:

• the categories of Personal Information we have collected about you;
• the categories of sources from which your Personal Information is collected;
• the business or commercial purpose of collecting or selling your Personal Information;
• the categories of third parties with whom we shares your Personal Information;
• the specific pieces of Personal Information we have collected about you;
• when and if applicable, the categories of Personal Information that we have sold about you and the categories of third parties to whom the Personal Information was sold, if applicable;
• deletion of your Personal Information; and
• an opt out of having your Personal Information disclosed or sold to third parties.

To submit a request, or designate an authorized agent to make a request under the CCPA on your behalf, please contact us at ccpa@thewealthpool.com, (844) 897-7526, or complete the web form located at [Link]. To verify your identity when you submit a request, we will match the identifying information you provide us to the personal information we have about you.  If you have an account with us, we will also verify your identity through our existing authentication practices for your account. Request will typically be honored within forty-five (45) days or less, but may take up to ninety (90) days based on the results of verification.

However, we will not be required to comply with your request to delete your Personal Information if it is necessary for us to maintain your Personal Information in order to:

• complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• debug to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;
• to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• comply with a legal obligation; or
• otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

We will not discriminate against you in the event you exercise any of the aforementioned rights under CCPA, including, but not limited to, by:

• denying goods or services to you;
• charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• providing a different level or quality of goods or services to you; or
• suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

This Privacy Policy is available to consumers with disabilities. To access this Privacy Policy in an alternative downloadable format, please click [here].

11. Communication With Children.

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Site. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on the Site or on or through any of its features, use any of the interactive or public comment features of the Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@thewealthpool.com.

12. We may change this Notice.

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you by e-mail to the primary e-mail address we have on file and/or possibly through a notice on the Site’s home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

13. Any questions?

For any questions, or to request further information regarding this Privacy Policy or our use and disclosure of Personal Information, please contact us at privacy@thewealthpool.com.