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Personal Capital Privacy Policy

Last updated on January 1, 2020

 

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.

Relationship with Personal Capital Progression Model

 

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 CategoryWhat do we share and why?
Our Service ProvidersAs 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 PartnersWe 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 RequirementsWe 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 CategoryWhat do we share and why?
Personal Capital ResearchFrom 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 ProvidersAs 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 CategoryWhat do we share and why?
Personal Capital Cash program account partnersAs 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 analysisIn 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 CategoryWhat 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 PartnersWe 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.


Our Use of Google Analytics

We use Google Analytics to help us understand how you interact with our website and mobile app, and to improve the user experience. To do this, we share a unique identifier with Google. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On, here.


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

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) provides a number of rights to California consumers. For a full description of your rights under the CCPA, please see Appendix A.


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.

 

 


 

Appendix A

California Consumer Privacy Act (“CCPA”) Disclosures

 

Who does the CCPA apply to?

The CCPA provides certain rights to California residents.


What rights do I have under the CCPA?

Broadly speaking, the CCPA grants California residents the following rights:

  1. a right to request that a business disclose the personal information that the business collects, uses, discloses and sells;
  2. a right to request that a business delete the personal information that the business has collected from them;
  3. a right to opt out of having their personal information sold by a business; and
  4. a right not to receive discriminatory treatment by a business for exercising their rights under the CCPA.

What personal information does Personal Capital collect about California consumers?

The chart below describes the categories of personal information Personal Capital has collected over the past 12 months, as well as the categories of sources from which the information was collected, the business purpose for which the information is collected, and the categories of third parties with whom Personal Capital shared personal information.

Please note that we also disclose the types of information we collect earlier in our Privacy Policy. However, the CCPA requires that we provide this information with reference to certain categories described in the CCPA and so we are restating the information here.


Category of Personal InformationExamplesBusiness Purposes
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Categories of Sources: Y, SP, TP
You provide this information when creating a dashboard, adding accounts, or signing up for a wealth management or Cash account. We may also obtain this information from service providers to verify your identity or provide services to you.1-7
Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Categories of Sources: Y, SP, TP
You provide this information when creating a dashboard, adding accounts, or signing up for a wealth management or Cash account. We may also obtain this information from service providers to verify your identity or provide services to you.

We do not store account numbers, credit or debit card numbers or login credentials for accounts that you link to your dashboard. We do not generally collect descriptions of physical characteristics, insurance policy numbers, physical characteristics, insurance policy numbers, education, medical or health insurance information, although if you are a wealth management Client and disclose this information to your advisor we may have a record of it.
1-7
Characteristics of protected classifications under California or federal law.
Categories of Sources: Y
You may provide your age, sex and marital status if you use our retirement planner. If you are a Personal Capital Cash customer you confirmed that you were a U.S. citizen.1, 2, 5-7
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Categories of Sources: Y, SP
If you have added accounts to your dashboard, we have collected transaction information reflected in those accounts. In addition, we have information about the investment and cash accounts you have opened with us.1-3, 5-7
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Categories of Sources: Y
We collect your IP address and cookies from your browser to recognize you and deliver a consistent experience when you visit our site and to measure the effectiveness of our marketing. We also collect information about how you interact with our website.1-3, 5-7
Professional or employment-related information.
Categories of Sources: Y
You may provide employment information when applying for a Personal Capital Cash account or if you are a wealth management Client.2, 5
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources: Y
We may use information you provide to tailor products or offers to you.1, 3-7

Note that we do not collect education, biometric or geolocation information.

Categories of Sources of Information

(Y) Most of the information personal information we have is provided by you either (a) through our website, including information you enter into our web site as well as information provided by your web browser or device, or (b) when speaking to a Personal Capital advisor or customer service agent.
(SP) We receive information from service providers who help us provide services to you.
(TP) In some instances, we purchase information from third parties. For example, we may purchase addresses for direct mail campaigns and sales leads from referral partners.

Business or Commercial Purpose for Collecting the Personal Information

(1) Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
(2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
(3) Debugging to identify and repair errors that impair existing intended functionality.
(4) Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
(5) Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
(6) Undertaking internal research for technological development and demonstration.
(7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Categories of Third Parties With Whom We Share Personal Information

We share the information described above with service providers to the extent necessary to provide the services you have requested and for the business purposes described above.


How Can I Exercise My Right to Opt Out of the Sale of My Personal Information?

Personal Capital does not sell any consumers’ personal information. We have not sold consumers’ information in the past 12 months, except that, until June 30, 2019, we allowed our aggregation partner, Yodlee, to make use of aggregated information for their own purposes, which may be considered a sale under the CCPA.


How Can I Exercise My Rights Under the CCPA?

If you have a Personal Capital dashboard account:

  • Log into your account and go to Settings.
  • Under the Privacy section, you will be able to request a report of the categories of information or specific information that we have collected about you or request that we delete your personal information.
  • In most cases, we will be able to authenticate your request using your dashboard login. In certain circumstances, if we believe it is necessary to authenticate your request and protect the security of your information, we may require additional information.

If you do not have a Personal Capital dashboard account:

  • Fill out an online request form
  • You will need to provide your full name, phone number, and email so that we can locate you and authenticate your identity. If you previously had a Personal Capital dashboard account, please provide the email and phone number you used to log into your dashboard.
  • We will authenticate your request by matching the information you provide against any information we have collected about you. In certain circumstances, if we believe it is necessary to authenticate your request and protect the security of your information, we may require additional information.

How Can I Designate an Authorized Agent to Exercise My Rights Under the CCPA?

You may use an authorized agent to submit a request on your behalf. To do so, the authorized agent must provide a copy of your written authorization to [email protected] along with a certification that such authorization or power of attorney has not been revoked and remains in effect. You will also be required to verify your identity directly with us.


Contact Information

If you have any questions about your rights under the CCPA, please contact [email protected].

 

Disclosure statement and acknowledgment: The statement is provided to you by ("Author") who have entered into a referral agreement with Personal Capital Corporation ("PCC"), through which Author will be paid between $70 and $150 for each person who uses this webpage to register with Personal Capital and links at least $100,000 in investable assets to Personal Capital's Free Financial Dashboard. Author is not affiliated with PCC and Author's services consist solely of referrals of prospective clients. As a result of this arrangement Author may financially benefit from referring potential clients to Personal Capital. No fees or other amounts will be charged to investors by Author or Personal Capital as a result of the Referral Arrangement. Investors that are referred to PCC and subsequently subscribe for investment advisory services provided by PCC’s affiliated adviser, Personal Capital Advisors Corporation (“PCAC”) will not pay increased management fees or other similar compensation to Author, PCC or PCAC as a result of this arrangement. Additional information about PCAC is contained in Form ADV Part 2A.