Personal Capital Privacy & Security Statement

Last updated on April 25, 2016

Personal Capital is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust.

We NEVER rent, sell or trade your personal information to anyone. Ever.

This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, and disclose and share with others user, consultation recipient, and/or client information provided to us through our marketing partners; the use of our web sites and applications; and other communications with representatives of Personal Capital Corporation and our wholly-owned subsidiaries. We refer to Personal Capital Technology Corporation and Personal Capital Advisors Corporation collectively as “Personal Capital” or “we” or “us”. We refer to those who visit our website and those who use our web and mobile applications collectively as “users”. Together with our Terms of Use, this Privacy & Security Statement governs your use of our services.

How to Use this Statement

This Statement explains, in plain English, how Personal Capital gathers and uses your information in the context of each of Personal Capital’s service offerings, including use of our financial dashboard, our delivery of advisor financial consultations, and delivery of our wealth management solution. In particular, we describe how your personally identifiable information is shared and/or disclosed, how we collect and use other non-personal information and how we address other privacy and security matters – such as our overall security practices, deletion of your information upon request and opting-out of marketing communications. Lastly, we describe methods for contacting Personal Capital if you have privacy or security questions, comments or feedback.

How We Collect & Use Your Personal Information

“Personal Information” is your personally identifiable information such as your name, email or mailing address, phone number, account credentials, account numbers and any other identifier that we gather from our web sites, mobile applications, or through communications with representatives of Personal Capital.

The types of information we collect depend on which of our services you choose to use. The following are the types of Personal Information we collect at various stages of our relationship with you:

Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.

When You Visit Our Website

When you visit our website, we may place a cookie on your computer so that our system can recognize you when you make a return visit. That cookie tells us your IP address and the type of browser you are using. These are the only types of information we collect when you visit our website but do not register or download our dashboard.

For Personal Capital Dashboard Software Users (“Dashboard Users”)

This section of the Statement is only relevant to you if you have registered with Personal Capital Technology Corporation’s dashboard software.

Personal Information We Collect

When you register for Personal Capital Technology Corporation’s dashboard service, we collect

When you register, and at times thereafter, we may present questions that ask you to submit demographic and other information. Responding to these surveys is completely optional. If you do respond by sending us other information, we collect that information and will retain it indefinitely.

When you use our dashboard software to aggregate your banking and other accounts, we collect

How We Use Your Personal Information

To allow you to register with Personal Capital Technology Corporation, including:

To allow you to Add Accounts (aggregate 3rd party data), including:

To provide you with Customer Support or Service Offerings:

To optimize systems and performance, provide comparisons and anonymous analysis:

When we include your data as part of our trends and analysis information, we always remove all personally identifiable information from that data first, so your information is aggregated with all others on an anonymous basis.

We may use certain third party service providers to help us provide you with some of the services mentioned in this Privacy & Security Statement. In doing so, we may provide your data (including your personally identifiable information) to those third party service providers, each of whom are required under contract with us to safeguard the 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 rent, sell or otherwise make commercial use of the data.

For Personal Capital Consultation Recipients

This section of the Statement is relevant to you only if you have elected to receive a personalized financial consultation from a licensed financial advisor employed by Personal Capital Advisors Corporation.

Personal Information We Collect

Upon your request for a Financial Consultation, we ask you to provide

How We Use Your Personal Information

To provide you with a Personalized Financial Consultation, including:

For Personal Capital Wealth Management Services Clients

This section of the Statement is relevant to you only if you have enrolled for our Wealth Management service, provided by Personal Capital Advisors Corporation.

Personal Information We Collect

Upon enrollment in our Wealth Management Service, you will be asked to review and agree to a number of written agreements and statements. Once you have completed the enrollment process, we will collect

How We Use Your Personal Information

To establish a Wealth Management relationship with you, including:

For All Personal Capital Users and Clients

With Whom We Share Your Personal Information

Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.

We may share your Personal Information:

To conduct everyday business

To comply with the laws, regulations and rules by which we are governed.

We may share your name and email address, and the name and email address of those you refer to us, with the referral fulfillment partners we retain as our third party referral program administrators.

Information that we share with others when you enroll in our Wealth Management Services is disclosed in documents we will present to you during the enrollment process.

Other Information We Collect From You

How We Collect and Use Your Other Information

We collect and utilize Other Information to optimize, secure and simplify your experience with us. Your Other Information is not disclosed or shared outside of Personal Capital.

For All Personal Capital Users and Clients

Additional Privacy & Security Information

For All Personal Capital Users and Clients

To protect Personal Information from unauthorized access and use, we use security measures that comply with relevant laws and regulations. Beyond this Privacy & Security Statement, we provide additional security measures, such as:

Bank Level Security: Personal Capital is powered using technologies and practices that many banks and other financial institutions use to protect customer information, such as SSL encryption for data in transit and AES encryption for sensitive data at rest. After initial account aggregation, we do not store your financial institution credentials in our systems or in our applications. Our dashboard account aggregation service is provided by an industry-leading third-party account aggregation service. (See “With Whom We Share Your Personal Information” above.) That service employs comprehensive financial data security standards and is subject to ongoing multi-agency financial institution regulatory examinations.

Device Authentication: When you register for our dashboard app, we recognize your device for enhanced security. If access to your dashboard account is attempted from another device, you will be notified by phone or email and access will not be granted unless you authorize the new device. Also, you may remove lost devices from your authorized device list to continuously protect from unauthorized access to your dashboard account.

No Money Movement: While using the dashboard app, you can only view financial account balances and transactions. You cannot transfer money between accounts, authorize spending or move money, safeguarding you from unauthorized money transfers from your financial accounts.

Account Monitoring: Our dashboard app allows you to monitor all your transactions for accounts linked to our dashboard, providing you with a comprehensive view of all account activities.

Reviewing and Updating your Personally Identifiable Information

You can view and update the profile and account information we collect for you by going to the “settings” function in our website and in our app. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.

Email Marketing Opt-out

When we communicate our own marketing offers to you, these communications are CAN-SPAM compliant, including the ability for you to opt-out of marketing communications.

Deletion/Retention of Personally Identifiable Information

Unless you request otherwise, we will retain the Personal Information we collect from you indefinitely.

Personal Capital, as a registered investment advisor, must 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 use our services, downloaded our dashboard or registered and established a user profile. However, we will not delete information that we are required to retain in order to comply with applicable laws and regulations.

How to Request Deletion of the Personal Information We Collect.

You may visit the troubleshooting section of our support web site for instructions on how to delete your Personal Capital account.

Alternatively, you may request your Personal Capital account be deleted by our support department by emailing [email protected] from the email address associated with your Personal Capital account, indicating “CANCEL” in the subject line of the message. After confirming you are the account owner we will remove Personal Information from our records and will only continue to retain such information as required by law.

Personal Capital’s Statement Regarding “Do Not Track” Signals

Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, Personal Capital does not respond to “do not track” signals. Consequently, Personal Capital, its third party service providers such as Google Analytics, and other third party websites and online services may indeed track and collect Personal Information about your online activities over time while navigating to, from and on our website and our mobile app and across those third party websites and online services, notwithstanding any “do not track” signals we may receive.

Advertising

We do not allow 3rd party advertising on our web site or applications.

Social Media

Personal Capital may integrate authentication or social experiences on social media platforms such as Facebook®, Twitter®, Google Circles and LinkedIn® that enable login or online sharing and collaboration among users who have registered to use such social media platforms. Any content you post, such as pictures, information, opinions, or any Personal Information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Protecting Children’s Privacy Online

Personal Capital is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our web sites or applications. We do not knowingly collect information from children under 13 without parental consent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.

Modifications to our Privacy & Security Statement

We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy & Security Statement and we will post the revised document on our website at https://www.personalcapital.com/privacy-policy.

Privacy & Security Questions, Comments or Feedback?

Please contact us.

Attention: Privacy & Security
Personal Capital Corporation and its wholly owned subsidiaries
1 Circle Star Way
Suite 189
San Carlos, CA 94070

Call toll-free 855-855-8005

Visit www.personalcapital.com

Email us at [email protected]