Last updated: July 18, 2021

This privacy policy (the “Privacy Policy”) describes how your personal information is collected, used, and shared when you visit allposit.com (the “Site”) or use any of the other services (together with the Site, the “Services”) offered by Allposit, Inc. (“Allposit” or “we”).

By accessing or using the Services, you consent to the information collection and data handling practices outlined in this Privacy Policy.

Personal Information We Collect

“Personal Information” is information that can be used to identify or contact you, such as your contact details, including your name, e-mail address and any other information that you provide in the course of requesting access and using the Services, including any data about your use of the Services, which may be collected automatically.

When you order or subscribe for Allposit services, or a prospective customer contacts us for information, we collect the following information directly from the user or customer: such individual’s name, email address and/or phone number. To open a user account, the user’s email address is required.

By voluntarily providing us with this data, you are consenting to our use of it in accordance with this Privacy Policy and you acknowledge and agree that it may be transferred from your current location to the offices and servers of Allposit and/or the authorized third parties referred to herein located in the United States. You may directly revise, correct or delete the Personal Information you provide via your Allposit user account.

Additionally, when you visit the Site or use the Services via the Site, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. As you browse the Site, we may use cookies to collect information about the individual web pages or products that you view, and information about how you interact with the Site.

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. Note that certain of our Services require certain cookies to be enabled; if all cookies are disabled, not all Services may be available to you.

Personal Information We Receive from Third Parties

Allposit offers data aggregation and analytics services of investment, retirement, deposit and other money-management accounts which Allposit customers link to the Allposit platform. When you link your Allposit account with your account(s) at one or more financial institutions, you are agreeing that these financial institutions provide Allposit with the information, including certain Personal Information (which may include: full name and address, account number and social security number), available on their statements relating to your accounts. You may disable or make changes to such account linking services at any time through your Allposit user account.

We do not otherwise receive Personal Information from Third Parties currently but may do so in the future, relating to prospective customers, via marketing campaigns run by third parties on behalf of Allposit.

Personal Information received by Allposit from third party websites or applications is subject to this Privacy Policy.

External Websites and Services

The Services may contain links to third-party websites or applications, including for purposes of providing account linking services or payment services. Allposit has no control over the privacy practices or the content of any of these websites or applications. As such, we are not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained therein. Please remember that when you use a link to go from the Services to another website or applications, our Privacy Policy does not apply to third-party websites or services. You should check the applicable third-party privacy policy and terms of service when visiting any other websites or applications, and before providing any Personal Information to such external websites or applications. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

How Do We Use Your Personal Information?

We use this Personal Information generally to fulfill any orders placed for Allposit services. Additionally, we use this personal Information to:

- communicate with you, manage our relationship with you, which includes sending administrative information to you, such as changes to our terms, conditions, and policies, and respond to customer and prospective customer queries;

- provide you with information or advertising relating to our products or services;

- analyze trends and track your usage of and interactions with the Services to improve your experience and our service offerings;

- diagnose or fix technological issues; prevent fraud or criminal activities, misuse of our products or services and ensure the security of our IT systems, architecture and networks;

- assess the success of our marketing and advertising campaigns;

- monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns;

- comply with legal obligations and legal process;

- respond to requests from public and government authorities, including public and government authorities outside your country of residence; and

- protect our operations.

We may use cookies, log file, device identifiers, location data and clear gifs information to remember information so that you will not have to re-enter it during your visit or the next time you visit the Services, provide custom, personalized content and information and help you efficiently access your information after you sign in.

In an ongoing effort to better understand our users and the Services, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services and products and the Services to current and prospective business partners and to other third parties for other lawful purposes.

How We Share Personal Information

We share the Personal Information we collect and receive only with trusted third parties and business partners to help us use such Personal Information to provide services to you, as described herein.

The account linking services for your accounts held at financial institutions are provided by Yodlee, Inc. The Personal Information you provide to Yodlee, Inc. will be treated in accordance with Yodlee, Inc.’s privacy policy which is available here: https://www.yodlee.com/legal/privacy-notice.

For the hosting of the Services, we use Amazon Web Services (AWS), a hosting and backend service provided by Amazon.com Inc. The Services are hosted on AWS servers located in the United States. The privacy policy for AWS is available here: https://aws.amazon.com/privacy/

In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including Personal Information, would be transferred to the surviving entity in a merger or the acquiring entity. If we are involved in a merger, acquisition or asset sale, or in the unlikely event of a bankruptcy, liquidation or receivership of our business, and your personal information becomes subject to a different privacy policy, we will provide affected users notice through the Services.

Finally, we may also share such Personal Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the lawful requests by governmental, self-regulatory or other public authorities (including for the purpose of meeting national security or law enforcement requirements); (b) to enforce our terms of use or to protect the security, quality or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of Allposit, our users, or others.

Selling Personal Information

Allposit will not rent or sell your Personal Information into third parties without your consent.

Cross-Border Storage and Processing

The Personal Information we collect or receive may be stored and processed in the United States or any other country in which Allposit or its affiliates, or service providers maintain facilities. Allposit may transfer information that we collect about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Allposit or its affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

For How Long Do We Keep Personal Information

We will maintain Personal Information in our records unless and until the earlier of the date you delete your Allposit user account, you ask us to delete this information or the date such information is automatically deleted in accordance with Allposit’s data retention policy in effect from time to time. Following termination of your user account, if any, Allposit may retain your Personal Information for a commercially reasonable time for backup, archival, or audit purposes. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

How We Keep Personal Information Secure

When you place an order online, your personal details and credit card information are encrypted using SSL encryption technology before being sent over the Internet. Although we cannot guarantee encryption or the privacy of your personal details, SSL makes it very difficult for your information to be stolen or intercepted while being transferred. All information sent to our credit card payment processors is in the secure SSL environment, which will protect it against disclosure to third parties.

Allposit otherwise uses commercially reasonable safeguards to preserve the integrity and security of all Personal Information Allposit collects from you or form third parties. However, Allposit cannot ensure or warrant the security of any information you transmit to Allposit or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

You are responsible for maintaining the secrecy of your unique password and user account information, and for controlling access to your email communications from Allposit, at all times.

Children

The Services are not intended for individuals under the age of eighteen (18), and Allposit does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register as users.

Your Rights

If you have a user account with the Services, you control your account information and settings: you may update your account information and email-communication preferences at any time by logging in to your account and changing your profile settings. If you do not have with the Services, you may exercise the rights to which you are eligible with respect to your Personal Information by contacting Allposit at any time using – see “Contact Us” below.

Opt-Out for Direct Marketing

You may opt out at any time from the use of your Personal Information for direct marketing purposes by contacting us or via changes you make to your Allposit user account. If you no longer want to receive notifications, change your preferences on your account settings or communicate your preferences to us via email support@allposit.com. You may opt out of receiving promotional communications from us by following the instructions in those communications. If you do opt out, we may still send you non-promotional communications, such as information about your account or your use of the Services. Please allow us a reasonable time to process your request. We will continue to contact you via email regarding the provision of our services and to respond to your requests.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Rights of a EAA Residents

If you are a resident of the European Economic Area (EEA), you have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a EEA resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Services), or otherwise to pursue our legitimate business interests listed above. Please note that your information will be transferred outside of Europe, including to the United States.

Rights of California Consumers and Residents

Under California law, specific disclosures are required, and California residents have additional rights regarding their Personal Information. Please review this section to learn more. You can download a printable copy of this Privacy Policy here https://allposit.com/privacy.

California Do Not Track Disclosure

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. We do not currently respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.

California Privacy Rights

The following details the categories of Personal Information that we collect and have collected over the past twelve (12) months: contact information, including full name and email address; information you submitted for purposes of accessing or using the Products; location information and Internet, including geolocation data; and customer service information.

Under the California Consumer Protection Act of 2018 (“CCPA”), a California consumer has the following special rights:

- right to request that the business disclose what Personal Information it collects, uses, discloses, and sells;

- right to request the deletion of their Personal Information collected by the business; and

- the right, at any time, to direct a business that sells Personal Information about the consumer to third parties not to sell the consumer’s Personal Information (“right to opt-out”).

Over the past twelve (12) months, we have not disclosed any Personal Information to any third parties, but in the future we expect to disclose the following categories of Personal Information to service providers or other parties for business purposes: contact information, including full name and email address; information you submitted for purposes of accessing or using the Products.

Based on our understanding of the term "sell" under the CCPA, we do not sell your Personal Information.

For any of the above-mentioned rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfil your request.

To exercise their rights and request copies of the data collected about them in the past 12 months, that their Personal Information collected by Allposit be deleted or to exercise their right of opt out, California residents may make a request at to support@allposit.com. Such request must include sufficient information to allow us to verify that you are the person about whom we have collected Personal Information and describe your request in sufficient detail to allow us to understand, evaluate, and respond to it. Opt-Out Requests may be cancelled by making an Opt-In Request.

We will work to respond to your valid request within 45 days of receipt. We will not charge you a fee for making a valid request unless your valid request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your valid request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

We will use the information you provide to make your CCPA rights requests to verify your identity, identify the Personal Information we may hold about you and act upon your request. We strongly recommend that you submit the email that you used when you registered with the Services. After you submit a CCPA rights requests using one of our forms, you will be required to verify access to the email address you submitted. You will receive an email with a follow-up link to complete your email verification process. You are required to verify your email in order for us to proceed with your CCPA rights requests. Please check your spam or junk folder in case you can't see the verification email in your inbox. If you are a California resident and have any questions regarding your CCPA rights under this Privacy Policy, please contact us at to support@allposit.com.

Right to be free from discrimination.

You may exercise any of the above rights without fear of being discriminated against. We are permitted to provide a different price or rate to you if the difference is directly related to the value provided to you by your data.

California Online Privacy Protection Act

CalOPPA requires a person or company in the United States that operates websites collecting personally identifiable information from individual consumers residing in California to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this Privacy Policy. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California Customers may request further information about our compliance with California’s privacy law, and may request to review and request changes to their Personal Information collected and stored by Allposit by e-mailing support@allposit.com .

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons, and will post any changes on the Services as soon as they go into effect. We encourage you to periodically review this page for the latest information on our privacy practices. You can always check the “last updated” date at the top of this document to see when the Privacy Policy was last changed.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a data request or a complaint, please contact us by e-mail at support@allposit.com.

We will respond to requests within a reasonable timeframe. We retain and use your information as necessary to comply with our legal and contractual obligations, statute of limitations, resolution of disputes, and enforcement of our agreements. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.