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This Privacy Policy (this “Privacy Policy”) explains how Adhesion Wealth Advisor Solutions, Inc., and Atria Investments, LLC (collectively, the “Company”) handle your personal information and data. We value your trust, and we’ve strived to present this policy in clear, plain language without complex legal jargon.

This Privacy Policy applies to all the products, services, apps and websites offered by the Company that post or include a link to this Privacy Policy. We refer to those products, services, apps and websites collectively as the “Services” in this Privacy Policy. We are located in the United States and collect, use, store and otherwise process your information and data in the United States.

Questions? For questions regarding this Privacy Policy or practices, contact us by emailing CCPACompliance@assetmark.com.

We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on and in the Services. We will also update the effective date. If we determine the changes are material, we will provide you with an additional, prominent notice as is appropriate under the circumstances, including via email.

By using the Services, you consent to the collection and use of the information described herein. Your continued use of the Services following the modification of this Privacy Policy constitutes your consent to and acceptance of such modifications.

Our Services

  • Customers and Users. Our customers use our Services as a wealth management platform for the recordkeeping of account information. We also provide business process outsourcing for managing account information and investment advisory services.

What Information About You Do We Collect?

When you use our Services, we collect information relating to you and your use of our Services from a variety of sources, described below. Later sections describe what we do with the information.

Information We Collect Directly From You Includes:

  • Application / Registration Information. When you submit an application or contract request forms, we collect data which may include details such as your name, email address, phone number, and employment information.

  • Support. You are required to have an account to communicate with our support team. We require you to provide your contact details, such as a name, address, phone number, and email address, for this purpose.

  • Responses You Intentionally Share. We collect your personal information and other data if you submit it to us in response to support inquiries.

  • Cookies and Other Tracking Information. We collect usage data, device data, referral data, and information from cookies and page tags (collectively, “Cookies”). Cookies are small bits of data we store on the device you use to access our Services so we can recognize repeat users, and record how users use the Services, which site a user comes from, the number of each user’s visits, and how long a user stays on the Services. Cookies help to improve software function, facilitate site navigation, and personalize a user’s experience of the Services. Each Cookie expires after a certain period of time, depending on what we use it for.

  • Information About You That We Collect From Third Parties.

  • We use third-party vendors to collect information about you and your use of our Services to provide us with analytics and tools to manage, improve, market and expand our Services.

  • Responses. We store and maintain user responses submitted to all support inquiries as well as submissions via any and all webforms.

  • Usage Data. The Company may also analyze user usage patterns to improve or optimize our Services.

  • To Manage Our Services. We internally use your information, including certain responses, for the following limited purposes:

  • To Monitor and Improve Our Services and Related Features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how users use our Services, and to monitor, troubleshoot and improve our Services. However, we do not use the non-public content of surveys (i.e., the content of questions and responses that you have not publicly shared) for these purposes.

  • To Aid Us In the Enforcement of Our Terms of Use.

  • To Prevent Potentially Illegal Activities.

  • To Create New Services, Features or Content (Public Data and Metadata Only). We may use public survey data and anonymized survey metadata (that is, data about the characteristics of a survey but not its non-public content), to create and provide new Services, features or content. For example, we may look at statistics like response rates, question and answer word counts, and the average number of questions in a survey and publish interesting observations about these for informational or marketing purposes.

  • To Contact You About Your Account. We occasionally send you communications of a transactional nature (e.g., service-related announcements, billing-related matters, changes to our Services or policies, or a welcome email when you first register). You cannot opt out of these communications since they are required to provide our Services to you.

  • To Respond to Legal Requests and Prevent Harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

  • Cookies. A Cookie is a small text file placed on the device you use to access our Services. Most browsers are set to accept Cookies by default, and by using our Services, you are consenting to our use of Cookies as described herein. We use information we obtain from Cookies for several reasons:

  • To Make Our Site Easier to Use. If you use the "Remember Me" feature when you sign into your account, we may store your username in a Cookie to make it quicker for you to sign in whenever you return to a Company website. For security reasons, we use Cookies to authenticate your identity, such as confirming whether you are currently logged into a Company website.

  • To Provide You with Personalized Content. We may store user preferences, such as your default language, in Cookies to personalize the content you see. We also use Cookies to ensure that users cannot retake certain surveys that they have already completed.

  • To Improve Our Services. We use Cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our Services and optimize the content we display to users.

What Do We Do with the Information We Collect?

If you would like to opt-out of the Cookies we employ on our Services, you may block, delete, or disable them through your browser, or set your browser to alert you when Cookies are being sent, as applicable:

  • The help function on most browsers contains instructions on how to set your browser to notify you before accepting Cookies or to disable Cookies entirely. Because each browser is different, please consult the instructions provided by your browser.

  • Some of our third-party partners may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here.

  • Some devices you may use may also have platform controls to make choices about Cookies. Please note that you must separately opt out in each browser and on each device and that Cookie-based opt-outs are not effective on mobile applications.

  • Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest-based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.

  • Some browsers transmit “do-not-track” signals. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. We currently do not take action in response to these signals.

If you choose to refuse, disable, or delete Cookies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting Cookies may in some cases cancel the opt-out selection in your browser.

How Do We Share the Data We Collect About You?

Rest assured that the Company does not sell your email address to any third parties. Nor does the Company sell your responses. To be clear, the Company does not sell your information to third parties, we only disclose your information to third parties (other than those in your organization) for a limited number of reasons:

  • Service Providers. We share your information with our service providers who help us to provide our Services to you. We give relevant persons working for some of these providers access to your information, but only to the extent necessary for them to perform their services for us. We also implement contractual and technical requirements to protect the safety and confidentiality of your personal information and ensure data is maintained, used only for the provision of their services to us, and handled in accordance with this Privacy Policy. Examples of service providers we utilize include email service providers, infrastructure-as-a-service, platform-as-a-service, data centers, and web traffic analytics tools. By using our Services, you authorize the Company to sub-contract in this manner on your behalf.

  • Research. We may disclose aggregated, anonymous, or anonymized data, including aggregated and anonymous responses, to third parties for market research, academic research, benchmarking, forecasting, trend research, or any other purpose. In all such instances, we will not disclose any identifiable information about users or our customers.

  • The Presence of a Cookie to Advertise Our Services. We may permit third parties to collect information from Cookies and disclose such information to third parties for those parties to display ads promoting our Services on other websites based on users’ online activities over time and across different sites, services, and devices. We may ask them to deliver those ads based on the presence of a Cookie but in doing so will not share any other information with the advertiser. You may opt-out of Cookies as described above. The information practices of these third parties are not covered by this Privacy Policy unless expressly stated otherwise herein.

  • Your Information If Required or Permitted By Law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us. Notwithstanding anything to the contrary in this Privacy Policy, the Company may disclose information regarding users (including personal information) pursuant to a valid subpoena or legal process. We will undertake good faith efforts to provide you with notice of any such subpoena or process, but this is not always possible or allowed by applicable law, and you acknowledge that we do not have a legal obligation to do so. Additionally, the Company may disclose information regarding users (including personal information) in order to protect the property of the Company or prevent any imminent damage to third party property or where there is a threat of personal injury.

  • Change in Business Ownership or Structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between Company entities, the Company will provide notice of such a transfer in accordance with applicable laws.

Do We Publicly Share Your Information?

Yes, but only in certain circumstances. Information you submit to publicly accessible blogs or community forums available through our Services may be read, collected, and used by others who access them. We are not responsible for any personal information you choose to submit in these publicly accessible areas of our Services.

Safety of Minors and COPPA

Our Services are not intended for and may not be used by minors. "Minors" are individuals under the age of majority in their place of residence. This age varies by jurisdiction, but generally includes those under sixteen (16) years old. The Company does not knowingly collect personal data from minors or allow them to register as users. If it comes to our attention that we have collected personal data from a minor, we may delete this information without notice. If you have reason to believe that we may have any information for or about a child under the age of sixteen (16), please contact us at CCPACompliance@assetmark.com.

What Are Your Rights to Your Information?

Depending on the jurisdiction, you may have the right to access, correct, update, restrict processing or object to processing, or delete certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you object this may affect our ability to provide our Services to you. While the Company will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable law. Please note that it may take some time to process your request, consistent with applicable law.

Specifically, you can:

  • Update Your Account Details. You can update your registration and other account information on the Settings page.

  • Capture Your Responses. You can take screenshots of your information and data, including but not limited to responses. We may in our discretion provide other tools to export the data.

  • Cancel Your Account. Deleting your account will not cause all the responses in the account to be permanently deleted, but will disable your access to any other Services that require a Company account.

  • Submit a Request. You can submit a request by email to CCPACompliance@assetmark.com. We will respond to your request, including any appropriate request to access, correct, update, restrict processing or object to processing, or delete your personal information within the time period specified by applicable law or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by applicable law (in which case we will block access to such data, if required by applicable law). If we are processing your personal data on behalf of a customer, we will promptly refer your request to our customer and support the customer in responding to your request.

For How Long Do We Retain Your Data?

We retain your data as long as necessary to provide our Services and to comply with our legal obligations. Within thirty (30) days after your data is no longer needed to provide our Services or comply with our legal obligations, we anonymize and aggregate your data permanently. However, we reserve the right to delete or purge such data.

Third-Party Data Sources

We obtain information about prospective customers and users from third party sources including data licensors and marketing company databases. We use the information to market Company Services.

Security

The security of your data and information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information submitted to us, intended to protect it from unauthorized access, destruction, use, modification, or disclosure. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure, and we are unable to guarantee the absolute security of your data and information.

Contact

If you have questions or concerns about our privacy policies and practices, you may call us at 833-620-0416 (toll-free) or email us at CCPACompliance@assetmark.com.