Personal Capital Privacy Policy

This Personal Capital Privacy Policy (the “policy”) describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to Personal Capital Corporation and our operating subsidiaries, Personal Capital Technology Corporation, Personal Capital Services Corporation and Personal Capital Advisors Corporation, collectively as “Personal Capital”, “we” or “us”. Together with our Terms of Use Agreement and Terms of Use, this Privacy Policy governs your use of our platform and services.

Personal Capital is committed to the protection of our visitors, users and clients (also referred to as “you” or “your”) privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust. Let us be clear - we do not rent, sell or trade your Personal Information.

 

How to Use this Privacy Policy

This policy describes if and how your Personal Information is shared and/or disclosed, how we collect and use other information and how we address other privacy matters – such as deletion of your Personal Information upon request, and opting-out of marketing communications. Lastly, we describe methods for contacting Personal Capital if you have privacy questions, comments or feedback.

Transparency is one of the best ways to earn your trust. The summary table below explains what information we collect from you and why based upon your relationship with us and as your relationship evolves with Personal Capital. This progression model is presented below.

 

How We Collect & Use Your Information

“Personal Information” means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (user id and passwords), social security number, government ID numbers and other information that can be used to identify you personally.

We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities. More information on this is provided below under the Visitors use case.

The following describes in further detail the information we collect at various stages of our relationship with you.

Visitors

When you visit any of our websites or download our apps, we consider you a Visitor. This section describes our privacy practices related to this use case.

What do we collect?	Why do we collect it?	Can you limit?
Personal Capital Cookies	To recognize you when you make a return visit and deliver overall a consistent experience	Most modern browsers allow you to delete or limit cookies.
Third-Party Tags and Cookies	To measure our marketing effectiveness	Most modern browsers allow you to delete or limit cookies, including third-party cookies however you may not be able to limit marketing tags entirely unless you do not visit our sites.
Internet Protocol (IP) Address	As part of the basic function of the internet To measure who is visiting us and where they are from	The only way to avoid this is not visiting our sites.
Browser Metadata Such as browser type, version, your operating system, system language, etc.	As part of the basic function of the internet To ensure we maintain a positive website experience for most used browsers	Browsers communicate this automatically however some third-party extensions may allow you to limit this.

What Visitor information do we share?

We share Visitor information in an anonymized format with our marketing partners for the purpose of measuring the effectiveness of our marketing campaigns.

 

Users

When you register, create a User Account on our Dashboard and begin using our services, we consider you a User. This section describes our privacy practices related to this use case. Keep in mind Users are also considered Visitors so this is information we collect in addition to what was described for Visitors.

What do we collect?	Why do we collect it?	Can you limit?
Email and Password	In order to establish your account and allow you secure access to it Email you about service updates, maintenance activities, security notifications, weekly summaries and other account related information Email you about service and/or product offerings, surveys and other marketing promotions Allow our Support team to contact you if needed	No, that is required to have a functioning account. You can opt out of marketing emails, see the Opt-Out section.
Phone Number	In order to secure your account with our Multi-Factor Authentication We may also, at your request or as appropriate for your situation and needs, contact you to recommend services and/or product offerings Allow our Support or Security team to contact you if needed, at your request	No, we require this for security purposes. You can, however, signify us that you want to be placed on our Do Not Call list. See the Opt-Out section.
[Optional] Financial Planning Information Includes your age, retirement age, retirement plan information, risk tolerance, family information and other demographic or related information	To provide you our free Retirement Planner service and design your personalized retirement plan To provide you with our Investment Checkup free service and perform an analysis of your investments (or other product features) If qualified, provide you with a free financial consultation with one of our advisors Conduct and publish anonymized aggregated research on personal finance trends	Yes, those are optional services which you are free to use or not use.
[Optional] Financial Account Information For third-party financial accounts you link - this includes your account credentials, passwords, security questions, transactions, balances, assets held, statements and other account information.	To provide you the holistic view of all of your finances in our Dashboard To provide you our free financial planning tools such as our Cash Flow tool, Budget tool and others To allow background automatic refreshes of your data such that your Dashboard is always up to date Conduct and publish anonymized aggregated research on personal finance trends	Yes, those are optional services which you are free to use or not use.
Product Use Information	Monitor and maintain system performance Identify most popular features and inform new features development Personalize your experience with Personal Capital	No, if you are a User we will collect this information

What User information do we share?

Personal Information

Sharing Category	What do we share and why?
Our Service Providers	As most businesses, we use third-party service providers to deliver the services mentioned in this Privacy Policy. In doing so, we provide some of your data (including your Personal Information) to those third party service providers, on a need to know basis. Those service providers are required under contract with us to safeguard your information. Except where expressly set forth in this policy, our third-party service providers may only use your data to provide services to us or to improve their services.
Marketing Partners	We also share users emails (or email hashes) and names in some cases with Marketing Partners working on our behalf and solely for marketing our services to you. We do not sell or allow your information to be used for any purpose other than to provide services to us. For example, if you participate in our referral program we will share your name and email with our referral management partner so you can be credited the referral bonus.
Security, Legal & Regulatory Requirements	We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, (v) if mandated by law or regulatory requirement, or (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

Anonymized Information

We may share anonymized information that is summarized or derived from information you provide to us as explained in the table below. Anonymized information is information that does not include any personally identifiable information.

Sharing Category	What do we share and why?
Personal Capital Research	From time to time Personal Capital performs analysis on personal finance and related topics, utilizing anonymized and summarized insights from our users and clients. Such research reports or findings may be shared with external publishers or published by us to further public awareness and understanding on financial topics of interest such as our “Hidden Beneath The Surface - What Americans are Paying in Advisory Fees” and others.
Service Providers	As most businesses, we use third-party service providers to deliver the services mentioned in this Privacy Policy. In doing so, we authorize some Service Providers to use anonymized information to provide services to us or to improve their services generally.

 

Personal Capital Cash Customers

If you are opening a Personal Capital Cash program account (when available), we consider you a Personal Capital Cash Customer. Personal Capital Cash Customers are also considered Users and Visitors and may also be an Advisory Client so this section describes the information that we collect in addition to what was described previously.

What do we collect?	Why do we collect it?	Can you limit?
Detailed Account Information Name Date of birth Social Security Number Physical and mailing address State ID, driver’s license or passport number Citizenship and country of birth Income and other financial information Occupation Contact, account & routing number, titling and fraud information for accounts you want to move funds to or from Other required personal information	To verify your identity and develop a behavior profile to enable us to better prevent fraud To facilitate the opening of a Personal Capital Cash program account, on your behalf, with our selected bank partner To enable our bank partners to comply with their customer identification programs to combat money laundering and prevent financial fraud To provide us with ongoing information required to provide continuing services to you To Satisfy legal and regulatory requirements	Yes, becoming a Personal Capital Cash customer is entirely voluntary. If you opt to become a Personal Capital Cash Customer, this information is required.

What Personal Capital Cash Customer information do we share?

Sharing Category	What do we share and why?
Personal Capital Cash program account partners	As a Personal Capital Cash Customer, you will own a program account provided through our banking partner and other participating program banks. Our banking partner for our Personal Capital Cash Customer program accounts is UMB Bank, National Association (“UMB”) and we will share Detailed Account Information with UMB. Our contract with UMB requires them to treat your information as confidential information. UMB’s Privacy Policy is available here.
Identity verification and fraud analysis	In addition, we will share some of your Personal Information and some Detailed Account Information with third-party identity verification providers and fraud analysis partners for the sole purpose of verifying your identity and preventing fraudulent transactions. These providers are required under contract with us to safeguard your information and not provide it to any third parties except as required to provide the services or as otherwise required by law, regulation or by court order. Personal Capital does not share this information with other third parties.

 

Advisory Clients

If you are opening a wealth management advisory account with us and utilizing our fee-based advisory service, we consider you an Advisory Client. Advisory Clients are also considered Users and Visitors and may also be Personal Capital Cash Customers, so this section describes information that we collect in addition to what was described previously, as applicable.

As part of our relationship with you as an Advisory Client, we will utilize the information we have on your financial dashboard in order to provide you with our holistic financial advice. We may also, at your request or as appropriate for your situation and needs, recommend third-party services to you.

What do we collect?	Why do we collect it?	Can you limit?
Detailed Account Information Name Social Security Number Mailing address Tax planning information Transferred securities information such as cost basis Your beneficiaries Contact information for investment accounts or banks you want to move funds from Your investment objectives, if not previously collected Other required personal information	Opening an account, on your behalf, with an independent securities brokerage trading and clearing custodian account or banking institution Enabling us to fund your accounts with your other investments assets or cash Providing the independent broker or banking institution with ongoing information required to provide continuing services to you Allowing us to perform tax analysis on the movement of assets, if applicable. Designing, implementing and managing your investment portfolio strategy Providing you with account statements, trade confirmations, tax information and other notifications related to the Advisory Service Satisfying legal and regulatory requirements	Yes, becoming an advisory client is entirely voluntary. If you opt to become an advisory client, this information is required.

What Advisory Client information do we share?

Personal Capital’s core business is wealth management. This means that our objective is to win you over as a Personal Capital Advisory Client. We do not rent, sell or trade your Personal Information. We do share some information as described in the table below.

Sharing Category	What do we share and why?
Your brokerage account(s)	As an advisory client of Personal Capital, you will have a custodial brokerage account to hold your personal portfolio. Our custodial brokerage partner for our advisory clients’ accounts is Pershing and we will share Detailed Account Information with them. You will have direct visibility, access, and interaction with Pershing while you are a Personal Capital Advisory Client. Pershing’s Privacy Policy is available here. Personal Capital does not share this information with other third parties.
Marketing Partners	We may share your name, mailing address and email address with our marketing partners to specifically exclude you from certain marketing campaigns. We contractually ensure that our partners do not use your information for any other purposes.

 

Additional Privacy Information and Your Privacy Rights and Resources

Affiliate Use and Required Disclosures

We may share Personal Information and other user information among our affiliated companies to provide services you have requested or to offer new services or products to you. When we talk about affiliated companies, we mean Personal Capital Corporation and its subsidiaries - Personal Capital Advisors Corporation, Personal Capital Services Corporation and Personal Capital Technology Corporation.

In addition, we may disclose Personal Information to third parties when required by law, regulation or by court order.

How to Request Deletion of the Personal Information We Collect

Personal Capital allows you to delete your account. You can consult our support article for instructions on how to do so. We will retain information on deleted accounts as required for legal and security purposes.

Opt-out Information

If you request to be added to our Opt-out lists, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to Opt-out of the following:

• Promotional or Product Notification eMails - see reference
• Advisor phone calls - notify your advisor at the time of the call to place you on the do not call list or reach out to the privacy team
• Physical Mailings - send your request to our support team or privacy team to be added to Opt-out list
• Short Message Service (SMS) Messages - Personal Capital supports industry standards for SMS Opt-out such as replying with “STOP” to opt-out of those messages.

For opt-out requests, please find contact information under “Privacy Questions, Comments or Feedback?” below.

Email Records

Personal Capital keeps business records, including emails you send to us, for five (5) years to meet our regulatory compliance requirements. This includes any email you send to our privacy, security or support teams.

Data Residency

Our services and data are hosted in the United States and are intended for individuals located within the United States.

US State Residents Privacy Notices

To exercise any of your rights described below, please find contact information under “Privacy Questions, Comments or Feedback?” below.

Nevada Residents

We are providing you this notice under Nevada state law. You may be placed on our internal Do Not Call List by contacting us.

In addition to contacting us, Nevada residents can contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, in writing at 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; by calling (702) 486-3132; or by emailing: [email protected]

Vermont Residents

Under Vermont law, we will not share any Personal Information we collect about Vermont residents with third parties, unless the law allows.

California Residents

Residents of California have the right to request a disclosure describing what types of Personal Information (if any) we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year.

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 websites 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 Policy

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

When changes to this Privacy Policy are material, we will provide notice to Personal Capital Cash Customers and Advisory Clients.

 

Privacy Questions, Comments or Feedback?

Please contact us*

Attention: Privacy Team
Personal Capital
3 Lagoon Drive
Suite 200
Redwood City, CA 94065

Call toll-free 855-855-8005
Visit www.personalcapital.com
Email us at [email protected]

*Note that the Privacy Team may not respond to automated requests or other requests that do not appear to be legitimate in nature.