Effective date: January 1, 2021
I. The Information That We Collect
A. INFORMATION THAT WE COLLECT DIRECTLY FROM YOU
We may collect information directly from you when you use our Services — for example, when you request to be connected to an advisor, or when you fill out forms or other fields on our web site. In such cases, we may ask you to provide us with one or more of the following pieces of information:
- Email address.
- Mailing address.
- Phone number.
- Date of birth.
- Your financial information, such as personal investments, personal income, personal expenses, your investable assets or other similar types of information.
- Demographic information such as age, gender, or other similar information when it is relevant to a particular financial product or service you have requested.
B. INFORMATION THAT IS AUTOMATICALLY COLLECTED
1. Information Collected
When you visit the Site, use one of our services, or open an email from Upfront Advisors, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:
- IP address or other device address or ID.
- Web browser and/or device type.
- Geolocation data, including if you use the Site on a mobile device.
- Hardware and software settings and configurations.
- Web pages or sites that you visit just before or just after visiting the Site.
- Pages you view on the Site.
- Your actions on the Site.
- Dates and times that you visit, access, or use the Services.
2. Cookie Information
When you use one of our services, we may send one or more Cookies (these are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both Persistent Cookies and Session Cookies. A Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to our services. Persistent Cookies can be removed. You can review your web browser “Help” file to learn how you can modify your cookie settings. If you delete, or choose not to accept, Cookies from the services, you may not be able to utilize the features of our services to their fullest potential. A Session Cookie disappears after you close your browser. You can also protect your information by downloading a 3rd party browser like Duck Duck Go.
3. Third-Party Web Beacons and Third-Party Buttons
We may implement third-party advertising or other content on the Site that may use clear GIFs or other forms of web beacons, which allow the third-party content provider to read and write Cookies to your web browser in connection with your viewing of the third-party content on the Site. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser Cookies, even when you do not interact with the button.
A number of different targeting and advertising programs may be used on this Site, including without limitation Google Analytics. We allow third parties, including non affiliated business partners, advertising networks, analytics providers, and other advertising service providers to collect information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. These third parties may use this information to display online advertisements across your browsers and devices, tailored to your interests and preferences. Information collected through web beacons, buttons, and similar technologies is collected directly by third parties, and we are not responsible for the privacy practices of these third parties. The information collected by these third parties in this manner is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative and participate in the industry’s opt out, available at http://optout.aboutads.info/#!/ or at http://optout.networkadvertising.org/#!/. Additionally, you may opt-out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout.
Due to differences between using websites and apps on mobile devices, you may need to take additional steps to opt out on both platforms. Many mobile devices allow you to opt out of interest-based advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.
C. INFORMATION WE COLLECT FROM OTHER SOURCES
II. How We Use Your Information
Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. We use the information you provide, for example:
A. To provide you the Services you request and enable non-affiliated third parties to provide additional services to you.
B. For fraud detection and information security.
C. We may use your e-mail address or other personal information (1) to contact you for administrative purposes such as customer service, (2) to address intellectual property, right of privacy or defamation issues related to content you have posted on the services, and/or (3) to send you promotional materials, offers, and/or messages related to the services and the activities of third parties we work with. Generally, you can opt out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Services, or by contacting us directly at firstname.lastname@example.org
D. To operate, maintain and improve the Services and create new features and functionality.
E. To understand and analyze usage trends and preferences of our users across different devices.
F. We may use Cookie Information and Automatically Collected Information to: (1) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (2) provide customized advertisements, content, and information across your devices; (3) monitor and analyze the effectiveness of Services and third-party marketing activities; (4) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (5) track your entries, submissions, and status in any promotions or other activities.
III. How We Share Your Information
A. We may disclose your information in connection with providing the Services and the operation of our business model. For example, we may share personal information, such as name, email, address, and other identifying information, with nonaffiliated third-party service providers to verify your identity in connection with your use of certain aspects of the Services.
B. We may share information collected directly from you with nonaffiliated third-party lending partners or third-party service providers in connection with your use of specific aspects of the Services. Some examples include but are not limited to:
- When you request additional or personalized information regarding financial product offers from third party financial service aggregators we partner with.
- When you report a complaint about a product or a third-party lending partner featured on our Site we may forward your complaint to that partner.
- When you request answers or advice through our Services, Upfront Advisor may provide certain of your information to third party experts, advocates, and advisors.
C. We may share automatically collected information such as IP address as well as de-identified information with nonaffiliated third-party lending partners when you leave our Site to go to a third-party partner site to request information or apply for financial products.
D. We may share your personal information with our wholly owned Upfront Advisor subsidiaries in order to provide you with recommendations on financial products and services that might be of interest to you.
E. We may share your information with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure. For example:
- For website, application development, hosting, data storage, maintenance, and other services for us.
- For internal marketing, delivery of emails, including promotional, marketing and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising.
- For fraud prevention and security purposes.
F. When you choose to share your own information on a publicly accessible area of the Site, such as a public profile page or any section where you can publicly submit questions to us or our third-party partners, that information will be available to anyone who is able to access that content, including other Site users. Additionally, questions you submit and answers provided by third parties may be posted on our Site and viewable by other users and the public.
G. We may share deidentified and/or aggregate analytics with third-party partners about how users interact with our services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the service.
H. We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
J. If you submit a request through one of our services, a third-party service provider may directly contact you with quotes or information via telephone, fax, and/or email. You may also receive telemarketing calls as a result of submitting the request, even if you are on the National Do Not Call Registry or any other similar registry.
L. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.
IV. Unsubscribing from Internal Marketing
A. UNSUBSCRIBING FROM EMAILS
If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.
C. You have the option to refuse any free consultations or offers for services provided after you submit a request to a third party through the Services.
V. Our Commitment to Data Security
We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services or store on the Site, and you do so at your own risk.
VI. Nevada Privacy Rights
Nevada residents may submit a request directing us to not sell personal information we maintain about them. To exercise this right, email us at email@example.com with the subject line: “Nevada: Request to Opt-Out.”
VII. California Privacy Rights
VIII. International Visitors
The Service is hosted in the United States and is intended solely for visitors located within the United States. The information we provide and the third-party products and services featured are tailored for the United States market only. You agree that if you choose to use the Services from outside the United States, you will be transferring your information outside of those regions to the United States for storage and processing.
IX. In the Event of Merger or Sale
Upfront Advisor reserves the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
XI. Our Contact Information