Personal Capital Privacy & Security Statement

Last updated on February 22, 2017

 

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 (as defined below) to anyone. Ever.

This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to Personal Capital Technology Corporation and Personal Capital Advisors Corporation collectively as “Personal Capital”, “we”, “us” or “us”. We refer to those who establish an account with us (“Account”) or otherwise use our service offerings as “users”. We refer to those who visit our website without logging into an Account or using our service offerings as “Visitors”. We refer to those who enroll in our Wealth Management Service as “Clients”. Together with our Terms of Use Agreement, this Privacy & Security Statement governs your use of our services.

 

How to Use this Privacy & Security Statement

This Privacy & Security Statement explains, in plain English, how Personal Capital gathers and uses your Personal Information in the context of each of Personal Capital’s service offerings, including use of our financial dashboard software service for aggregating your accounts (“Dashboard”), our delivery of personalized advisor financial consultations (“Consultation Service”), and delivery of our personalized wealth management service (“Wealth Management Service”). In particular, we describe how your Personally 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 Personal 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 that can be used to identify you personally.

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 also collect and use non-Personal Information that we obtain from your website and mobile app activities, such as browser information and information obtained from our use of cookies and pixel tags. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities. For more information about our collection and use of this category of information, please refer to the section “How We Collect and Use Non-Personal Information From Your Browser and App Activities” below.

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:


For Visitors

This section of the Privacy & Security Statement is relevant to you if and when you are a Visitor.

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 are a Visitor. For information about how we use this information, please refer to the section “How We Collect and Use Non-Personal Information From Your Browser and App Activities” below.


For Personal Capital Dashboard Users

This section of the Privacy & Security Statement is relevant to you if you have registered to use the Dashboard.

Personal Information We Collect

When you register for our Dashboard, we collect:

  • Your name;
  • Your email address;
  • Your phone number; and
  • Other optional information you may provide, such as your age, investable assets and risk tolerance.

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. For further information about the use of your Personal Information for surveys, please refer to “For All Personal Capital Users” below.

When you use our Dashboard to aggregate your banking and other accounts, we collect:

  • Account login credentials (including user names and passwords) for the accounts you link to our service;
  • Account security and/or challenge questions for those accounts; and
  • Other information from those accounts that you link to our service (including account balances, transactions and holdings)

How We Use Your Personal Information

To allow you to register for an Account, including:

  • Creating an Account to use our Dashboard;
  • Authenticating your device to access our services; and
  • Communicating to you about updated features, provide feedback about our services, or maintenance activities related to providing you with our services.

To allow you to add accounts (aggregate third party data), including:

  • Securely gathering account balances, statements, transactions and holdings from your financial institutions;
  • Displaying personalized dashboards and financial visualizations for you; and
  • Providing you with contextual and relevant observations and insights;

To provide you with customer support or service offerings:

  • Responding to and resolving your inquiries and requests via email or by phone; and
  • Offering you our other services, including free Consultation Service and our Wealth Management Service.

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

  • Monitoring system performance and data accuracy for optimization and user experience;
  • Providing you comparisons of your financial situation (e.g., investment risks & returns, financial ratios) relative to aggregated user data to better understand your financial situation;
  • Personalizing your user experience with Personal Capital; and
  • Publishing trends and analysis for our user base (e.g., America’s balance sheet, geographical financial patterns).

When we include your data as part of our trends and analysis information, we always remove all Personal 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 Personal 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 Personal Information may some of them be contractually allowed to rent, sell or otherwise make commercial use of the data.


For Personal Capital Consultation Service Users

This section of the Privacy & Security Statement is relevant to you only if you have elected to receive our Consultation Services from a licensed financial advisor employed by Personal Capital Advisors Corporation.

Personal Information We Collect

  • Your financial goals;
  • Your investment objectives;
  • Employment and income information about your household;
  • Retirement planning information about your household; and
  • Other information you elect to share with us about your spouse/partner and/or beneficiaries.

How We Use Your Personal Information

To provide you with the Consultation Service, including:

  • Informing you about existing risks and opportunities within your current investment portfolio;
  • Providing you with customized investment insights; and
  • Personalizing your user experience with Personal Capital.

For Clients

This section of the Privacy & Security Statement is relevant to you only if you are a Client.

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:

  • Your mailing address;
  • Your tax data, such as tax bracket and security cost basis;
  • Information about your beneficiaries;
  • The account login information for your bank and investment accounts;
  • Your investment objectives; and
  • Your other personal user profile information.

How We Use Your Personal Information

To establish a wealth management relationship with you, including:

  • Establishing a discretionary investment management relationship with you, only upon your explicit request;
  • Opening an account, on your behalf, with an independent securities brokerage trading and clearing custodian account or banking institution;
  • Providing you with account statements, trade confirmations, tax information and other notifications related to the Wealth Management Service;
  • Providing the independent broker or banking institution with ongoing information required to provide continuing services to you;
  • Creating and continuously managing your investment portfolio strategy, aligned with your investment objectives, tax data and personal preferences.
  • Personalizing your Client experience with Personal Capital.

For All Personal Capital Users

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.

  • If you have registered to use our Dashboard to aggregate your banking and other financial accounts, we will transmit your account credentials to those third party institutions where you hold accounts to gather and maintain your account balances, transactions and holdings used to provide our services. (Read more about our secure handling of your credentials);
  • We will share your Personal Information with our wholly-owned subsidiaries (i.e., Personal Capital Technology Corporation and Personal Capital Advisors Corporation) for everyday business purposes, such as sharing information about your experiences or transactions, to provide financial insights and advice and improving your user experience.

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.

We may use the email address and other contact information that you provide to us to send you surveys as part of our marketing activities. Responding to those survey solicitations is completely voluntary.

We may share the email address and other contact information that you provide to us with third parties with whom we contract to conduct the surveys just mentioned above on our behalf. Our agreements with those third party contractors prohibit them from using your email address or other contact information for any other purpose or from sharing that information with other third parties.

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

 

How We Collect and Use Non-Personal Information From Your Browser and App Activities

We collect and utilize the kinds of non-Personal Information mentioned in the second paragraph under “How We Collect & Use Your Personal Information” above to optimize, secure and simplify your experience with us. This information is not disclosed or shared outside of Personal Capital.

For All Personal Capital Users

  • Your Browser or Device
    Certain information is collected by most browsers or applications, such as your “user agent string”, to help us determine your computing device type, operating system version and Internet browser type and version. We use this information to ensure that our web sites function properly and for security purposes.
  • Your Cookies
    Cookies are pieces of information stored directly on the computing device you are using. Cookies we use do not contain or capture Personal Information. Cookies allow us to collect information such as your browser type, time spent on our web sites and which of our pages you visited. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience and to recognize authorized devices to secure your use of our services. We also gather statistical information about web site usage in order to continually improve the design and functionality and to assist us with resolving technical support questions. Additionally, we use cookies on our web sites and the sites on which we advertise to track advertising performance and to collect aggregate data on web page viewing and mobile app usage. Cookies may be connected to third-party companies or websites. The privacy practices of the companies placing such cookies are governed by the privacy policies of such third-party companies or websites. As an example, Google Analytics measures the performance of advertisements by placing cookies on your computer when you click on an advertisement. When you visit the website which you clicked on, you will have cookies placed on your computer. As a result, we and Google will be able to tell that you saw the ad delivered by Google. The privacy practices pertaining to these cookies are governed by our Privacy & Security Statement and Google’s Privacy Policy. Cookies are not used to collect or disseminate any Personal Information. You can manage the placement of cookies on your computer through the features found in most Internet browsers. You can also delete cookies that have already been placed on your computer. Consult the “Help” function of your browser to explore your options.
  • Pixels Tags
    Personal Capital deploys Pixel Tags as 1x1 pixel images (GIFs), used to track your access to web site pages, and HTML-formatted email messages. We use pixel tags to measure the effectiveness of our communications, the success of our marketing campaigns, compile statistics about usage and response rates, and to assist us in resolving user questions about the use of our services.
  • Your IP Address
    Your IP Address is a number assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged whenever you visit our web sites or applications, along with the page(s) that were visited. We use IP Addresses, individually and collectively, for purposes such as calculating usage levels, helping diagnose technical problems and supporting our web sites and applications. Additionally, we use your IP Address to assist in fraud detection and authentication to better protect your security.

 

Additional Privacy & Security Information

For All Personal Capital Users

To protect users’ 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 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 or log into your Account to use the Dashboard, we recognize your device for enhanced security. If access to your 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 Account.

No Money Movement: While using the Dashboard through our mobile 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 mobile app that allows you to use the Dashboard allows you to monitor all your transactions for accounts linked to your Account, providing you with a comprehensive view of all account activities.


Reviewing and Updating your Personal Information

You can view and update the profile and information associated with your Account that we collect for you by going to the “settings” function in our website and in our mobile 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 Personal 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 Account.

Alternatively, you may request your Account be deleted by our support department by emailing [email protected] from the email address associated with your 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 third 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
One Circle Star Way
First Floor
San Carlos, CA 94070

Call toll-free 855-855-8005

Visit www.personalcapital.com

Email us at [email protected]