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Privacy Policy

Last Updated on January 9, 2017

1. Introduction
Retirely, Inc. is committed to respecting the privacy rights of our customers, visitors, and other users of Retirely. Everything we offer is referred to in this privacy policy (as amended from time to time, the “Privacy Policy”) collectively as the “Services.” This Privacy Policy is only applicable to our Site or Services and information obtained by us from any of our marketing affiliates and not to any other websites that you may be able to access from the Site or any website of Retirely’s business partners, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. Your use of the Services is governed by this Privacy Policy and the Terms of Use.

BY USING THE SITE OR SERVICES, OR BY REGISTERING WITH US, YOU (A) ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND (B) CONSENT THAT WE WILL TRACK, COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE SERVICES ON BEHALF OF AN INDIVIDUAL OR ENTITY OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

RETIRELY IS NOT A REGISTERED INVESTMENT ADVISOR AND DOES NOT OFFER INVESTMENT ADVICE. RETIRELY IS NOT A THIRD PARTY PAID SOLICITOR FOR INVESTMENT ADVISORS. RETIRELY IS PROVIDING A TECHNOLOGY PLATFORM AND FORUM TO MEMBERS OF THE PUBLIC, WHO MAY BE SEEKING TO LOCATE A REGISTERED INVESTMENT ADVISOR.

2. Traffic Data Collected
We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring source that may have sent you to the Site; and (6) other information associated with the interaction between your browser and the Site (collectively “Traffic Data”).

3. Personal Information Collected
We may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) contact data (such as your e-mail address, phone number, and Retirely password); (2) demographic data (such as your gender, your date of birth, and your zip code); and (3) financial data. If you communicate with us by, for example, e-mail or letter,any information provided in such communication may be collected as Personal Information.

4. Interactive and Installed Tools
We also collect other information, some of which may be Personal Information that you voluntarily provide to us when you choose to use some of the Services such as using the Retirely APP to search for investment advisors (“Advisors”). We also collect information you provide voluntarily in free-form text boxes on the Site and through responses to surveys, questionnaires, and the like. You may elect to use certain Services such as the APP that requires you to download and install software on your phone. The Installed Tool may collect and transmit information solely relating to use of the Installed Tool and for the purpose of providing you the relevant Services, for example, by informing Retirely when a user is logged on and available to receive update or alert notices.

5. Cookies
We may use small computer files that are transferred to your computer’s hard drive that contain information such as user ID, user preferences, lists of pages visited, and activities conducted while browsing the Site (“Cookies”) to help us improve our Site by tracking your navigation habits and to store some of your preferences. Generally, we use Cookies to customize your experience on our Site and to store your password so you do not have to re-enter it each time you visit the Site. Cookies do not allow our site to gain access to other information on your computer. At your option, expense, and responsibility, you may block Cookies or delete Cookies from your hard drive. However, by disabling Cookies, you may not have access to the entire set of features of the Site.
In addition, our business partners may use Cookies to provide us with anonymous data and information regarding the use of our Services. Specifically, some of our business partners use Cookies to show Retirely ads on other sites on the internet as a result of you using the Services. Such Cookies do not contain any Personal Information. You may opt out of receiving Cookies placed by such third party vendors by visiting the Network Advertising Initiative opt out page (www.networkadvertising.org/choices/#completed).

Other Cookies used by our business partners may collect other non-personally identifying information, such as the computer’s IP address, type of operating system, type of internet browsing software, what web pages were viewed at what time, the geographic location of your internet service provider, and demographic information such as gender and age range. This information is used to provide Retirely with more information about our users’ demographics and internet behaviors.

We do not link the information stored in these Cookies directly to any of your Personal Information you submit while on the Site. The Advisors on the Site are not permitted to use Cookies in connection with the site in any way.

6. Web Beacons
In limited circumstances we also may use tiny graphic image files imbedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser (“Web Beacons”) to collect anonymous, non-personal information about your use of our Services and your use of emails, special promotions, or newsletters we send to you. The information collected by Web Beacons allows us to statistically monitor how many people are using the Services or opening our emails, and for what purposes.

7. Website Analytics
We may use third party website analytics services in connection with the Services, for example, to record mouse clicks, mouse movements, scrolling activity, as well as any text that you type into the Site. These website analytics services do not collect Personal Information that you do not voluntarily enter into the Site. These services do not track your browsing habits across websites that do not use their services. We use the information collected from these services to identify usability problems and to make the Services easier to use. The recordings will never identify you or your account; they only record anonymous user information.

8. Storage
We may store all Traffic Data and review postings indefinitely, even after such information is deleted from the live system, and may archive such information elsewhere. We will modify or delete your Personal Information if you request that we do so, but we may still retain certain Personal Information for the reasons described in Section 19 below.

9. Information Provided on Behalf of Children
The Children’s Online Privacy Protection Act (“COPPA”) severely restricts what information can be collected online from children under the age of 13. For this reason, children under the age of 13 in the United States are prohibited from using the Services. The Services are not directed at children, and Retirely does not knowingly collect any information from individuals under the age of 13. If we learn that we have received any information from an individual under the age of 13, we will use that information only to respond directly to that child (or a parent or legal guardian) to inform him or her that he or she cannot use the Services and subsequently we will delete that information from our own servers. If you are a parent or legal guardian of a minor child, you may, in compliance with the Terms of Use, use the Services on behalf of your minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Information as otherwise provided herein

10. Retirely’s Use of Your Information
We do not sell, trade, or otherwise transfer your Personal Information to outside parties except to trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep your Personal Information confidential. We may transfer information about you to another company in connection with our merger or acquisition.

We may share your contact data, demographic data, and other Personal Information with the Advisors we contract with. Your use of the Services may also require Retirely to use your Personal Information to establish appointments for you with your Advisors and to allow your Advisors to refer you to, and make appointments with, other Advisors on your behalf. We may also use your anonymized Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.
We may use your Personal Information to send you information about certain resources or Advisors. We may use your contact data to send you information about Retirely or our products or Services, to contact you when necessary, and in conjunction with your use of certain services. We may use your demographic data or other data to customize your experience through the Services, in emails, and in other communications, displaying content that we think you might be interested in and according to your preferences. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

12. User Choice
You may choose not to provide us with any Personal Information. In such an event, you can still access and use some of the Services; however you will not be able to access and use certain key features of the Services that require your Personal Information.

13. Confidentiality and Security
Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to: (1) comply with a court order or other legal process; (2) protect the rights, property, or safety of Retirely or another party; (3) enforce our Terms of Use; or (4) respond to claims that any posting or other content violates the rights of third-parties.

14. Advisors
Advisors and their employees and agents should be particularly aware of their obligations of confidentiality. Each Advisor is obligated to have its own privacy policy, which they are required to provide to you prior to, or at the time, of entering into any formal advisory agreement with you. Retirely is not a party to such Advisors’ privacy policy and does not have, and will not accept, any obligations of confidentiality with respect to any communications other than those expressly stated in this Privacy Policy and Retirely’s Terms of Use.

15. Public Information
Our Site has two general areas. The first area is accessible by the public while the other area is protected and only accessible to authenticated Users. However, any information that you may reveal in a review posting or other online discussion or forum on our Site will be accessible to your social network contacts/friends, so you should think carefully before posting any personally identifiable information on our Site. What you write may therefore be seen or collected by third parties and may be used by them or others in ways that we are unable to control or predict.

16. Security
As a Retirely user, your privacy and security always comes first, and our dedication to the safety and protection of your Personal Information remains as strong as ever.

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information on our Site, we encrypt that information using secure socket layer technology (“SSL”).

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, you should nevertheless understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

17. Lost or Stolen Information
You must promptly notify us if your contact data is lost, stolen, or used without permission. In such an event, we will remove that contact data from your account and update our records accordingly.

18. Updates and Changes to Privacy Policy
We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy, so you should review it frequently. If we do, then we will post the amended Privacy Policy on the Site; we may also attempt to notify you in some other way. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

19. Controlling Your Personal Information
As a registered user of the Services, you can modify some of the Personal Information you have included in your profile or change your username by logging in and accessing your account. Upon your request, Retirely will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may be impossible to remove your account without some residual information being retained by Retirely. Registered users who wish to close their account can do so by e-mailing our support team at [email protected]

20. Links to Other Websites
The Site may contain links to third party websites to which Retirely has no affiliation. Retirely does not share your Personal Information with those websites and is not responsible for their privacy practices. Some websites may have the look and feel of our Site. Please be aware that you may be on a different site and that this Privacy Policy only covers our Site. As a convenience to our users, many of the Advisor pages on our website contain links to information created and maintained by the Advisor or other organizations. Retirely does not control, and is not responsible for, the accuracy, timeliness, or even the continued availability or existence of this outside information. Opinions expressed on Advisor pages and other sites are not those of Retirely, nor does Retirely endorse, warrant, or guarantee products or services described or offered on Advisor pages or other sites. Retirely is not responsible or liable for the contents of any websites linked on our Site, including those linked on an Advisor’s page. Should you decide to visit one of these third party websites, we suggest that you read its privacy policy.

21. Contacts
If you have any comments, concerns or questions about this Privacy Policy, please contact us at [email protected].