Last updated: September 25, 2017
Your questions and comments on this policy are welcome at firstname.lastname@example.org.
The term “Personal Information” is used throughout this document to describe data that can be associated with a specific individual and can be used to identify that individual. Personal Information does not include data that has been anonymized so that it does not identify a specific individual.
2. PERSONAL INFORMATION COLLECTED
When you register an account with plynty or use its Services, you voluntarily provide us information about yourself. What Personal Information we collect is dependent upon what you choose to do. The following are categories of the Personal Information we gather:
plynty Account Information: When registering a new plynty account (the “Account”), the Personal Information collected includes your name, email address, mobile number, and account credentials for use during authentication and account access.
Demographic information: The minimum Personal Information needed to provide you cursory financial insight and recommendations is marital status, date(s) of birth, and current annual household income.
Financial Account Information: Any in depth analysis of your financial situation and strategies requires a gathering of financial account information such as but not limited to pension and annuity payout schedules, social security benefits, investment holdings, balances and planned contributions, mortgage obligations, and rental and alimony incomes. Financial account information may be entered manually by you or it may be collected automatically from your financial institution accounts. Automated collection is an optional service, and is facilitated by a trusted third party institution. The login credentials for your financial institution accounts are saved by the third party, not by us.
Tax identification: With some optional transactions as such opening a brokerage account, your full legal name, permanent mailing address, and tax information is collected, as required by law.
Service Information: Your trust in and satisfaction with the plynty Services are taken seriously. Our customer support team may collect additional information about you or from you. Examples may be assistance we provide in resolving a problem you encountered, or your response to a satisfaction survey.
We collect Personal Information with one sole purpose: to deliver the personalized financial service and customer support that you request.
3. OTHER INFORMATION COLLECTED
When you visit our website https://www.plynty.com or use the plynty mobile app, we may collect other technical information. Most is anonymized information; some is Personal Information. The following are the categories of other information we collect.
Device Information: We collect what type of device you are using and what version of the operating system and browser are being run. We collect this information to optimize our applications for your user experience. We do not store on your device Personal Information or any advertising related HTML.
Mobile Analytic Information: We use analytics software from Ionic® to help us better understand the performance of our mobile app on your device. This software may record information such as how frequently you use the plynty mobile app, what events occurred within the app, and app performance data. This information is anonymized. We do not associate information collected by the analytics software to any of your Personal Information.
We also integrate analytic software from Facebook® and other third parties to help us better understand how our new users engage with and find value with our app. This software may record information such as how frequently people use the app, what pages they visit on the app, and what actions they take on the app. We use the information collected by this integration to improve the app and understand the effectiveness of our marketing campaigns. The information we receive is anonymized and we do not associate it with your Personal Information.
Website Analytic Information: We use analytics software from Google®, Facebook®, and other third parties to help us to better understand how visitors use our web site. This software may record information such as how frequent users visit our site, what pages they visit when they do, and what other site was visited immediately prior to our site. We only use the information collected by this analytics software to improve the site and to understand the effectiveness of our marketing campaigns. Only the Internet Protocol (ISP) address is collected, which was assigned to you on the date you visited this site, not your name or other identifying information. This information is anonymized. We do not associate information collected by the analytics software to any of your Personal Information.
4. USE OF COLLECTED INFORMATION
Our sole purpose in collecting Personal Information is to provide you with highly secure and valued financial planning services. Your Personal Information may be used to:
- deliver the personalized financial services and customer support you request;
- monitor and improve our Services for you;
- send updates about new features that we are offering within the mobile app;
- perform fiduciary duties as required by law;
- intercept potentially fraudulent or illegal activities.
5. DISCLOSURE OF PERSONAL INFORMATION
If the plynty app is used to aggregate your banking and other financial institution accounts, your account credentials will be shared with those third party institutions where you hold accounts so that account balances and holdings may be collected to provide our Services.
If the plynty mobile app is used to request financial products such as a life insurance quote or creation of a brokerage account, we will transmit only the minimum necessary Personal Information, upon your consent, to those third party institutions so they may fulfill your request.
It is possible that we may need to disclose Personal Information when required by law. We will disclose such information wherein we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on our company or to exercise our legal rights or defend against legal claims.
Third party service providers are required under contract with plynty, LLC to keep private and secure your Personal Information, and to use it only to provide services to us. Per our contracts, only after these providers have removed all personalized information may some of them be contractually allowed to make sole commercial use of the anonymized, non-personalized data.
6. PROTECTION OF PERSONAL INFORMATION
We protect your Personal Information from unauthorized access using security measures that comply with governing U.S. laws and regulations, and that mimic what banks and other financial institutions use to protect Personal Information from hackers and unauthorized access. Our servers reside in top-tier cloud computing centers within the U.S. Your data is SSL encrypted when in transit and AES encrypted while on our servers. Our data security policy is comprehensive and is tested regularly by third party cybersecurity experts.
If you choose to use our Services we will make reasonable efforts to secure your Personal Information. Despite our efforts, we cannot guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of our safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your plynty sign-in password.
If plynty is made aware of a systems security breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the plynty mobile app, you agree that plynty may communicate with you electronically. plynty may post a notice on the website if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) please notify us at email@example.com.
7. ACCESS TO PERSONAL INFORMATION
You can review, update, and delete your Personal Information in your profile at any time by signing into your plynty account on your mobile device. If you encounter any problems, you may alternatively contact us at firstname.lastname@example.org.
8. RETENTION OF PERSONAL INFORMATION
Unless you contact us and request otherwise, we will retain the Personal Information collected from you indefinitely. Compendium Advisor is the registered investment advisor of plynty, LLC and is obligated to comply with certain legal and regulatory requirements pertaining to record retention. We will respond to any requests we receive asking that we delete Personal Information that we possess from those who used our Services. However, we may not delete information for which we are required to retain in order to comply with applicable laws and regulations.
9. PERSONAL INFORMATION OF CHILDREN
Our Service is not directed to individuals under the age of eighteen (18), and those individuals should not disclose Personal Information through our website or app. If you learn that your minor child has provided us with Personal Information without your consent, please contact us at email@example.com.
10. DEVICE AUTHENTICATION
When you sign in to the plynty app, you will be asked for something you know, which is your password, and something you have, which is your mobile device. Plynty will securely send you a numeric code via SMS during the act of you signing in. The plynty app uses your password and this private code to authenticate that you are the person who is signing into your plynty account.
11. COOKIES AND USAGE COLLECTION
11.1 Cookie and Pixel Technologies
A cookie is a small text data files that a web site you visit may save on your computer, mobile phone or other device. A cookie enables a web site to recognize your device when you subsequently revisit the site. A cookie includes typically an anonymous unique identifier. Pixels are small graphic images used to measure the frequency of views of a web page. Pixels are commonly placed in email messages and newsletters to learn whether the messages were opened and the links were actually clicked.
11.2 Cookie and Pixel Use
Session cookies are set by plynty to enable the plynty Services to work as intended. These cookies are necessary to enable you to navigate and use the plynty web site and the plynty mobile app. You may opt out of any of the session cookies; but in doing so, various functions of the website and mobile app may be unavailable to you or may not work as intended.
Analytic cookies, pixels and similar technologies help us track and understand how our web site and our mobile applications are used, and thereby learn how to improve our customer service. Examples of the information includes, but is not limited to when you visited the site last, how long you stayed on the site, which pages you visited, and what was your approximate geographic location at the time of use. This information is anonymized. We do not associate information collected by the analytics software to any of your Personal Information.
We use Google Analytics® to understand our web site visitations. To learn more about Google Analytics and your privacy, visit http://www.google.com/analytics/learn/privacy.html. To opt out of being tracked by Google Analytics when using our website, visit http://tools.google.com/dlpage/gaoptout.
We use Ionic analytics to understand our mobile application usage. To learn more about Google Analytics and your privacy, visit http://docs.ionic.io/docs/io-introduction
13. OUR CONTACT INFORMATION
13880 Dulles Corner Lane, Suite 300
Herndon, VA 20171
Email us at firstname.lastname@example.org