True Link Privacy Policy
This Privacy Policy explains how True Link Financial, Inc. and its subsidiary, True Link Financial Advisors, LLC (collectively, “True Link,” “Company”, we,” “our” or “us”) collects, uses, discloses, and protects information through our online services, websites, mobile applications, use of True Link financial services products and the associated software platform, the use of the trust administration software and record-keeping platform, and any other software provided on or in connection with the services and also any and all communications with us via phone, email, text or otherwise (each, a “Service” and collectively, “Services”).
When you use the Services, you consent to our collection, use, disclosure, and protection of information about you as described in this Privacy Policy.
BY ACCESSING OR USING THE SERVICES, YOU AGREE TO THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICE(S).
1. Collection of Your Information.
We may collect and store various information about you including, for example, information that you provide to us, information that we automatically collect through your use of the Service, and information from publicly available sources or third parties, as further detailed below. If you are an individual who utilizes our Services to obtain a financial product or service through us, we will use and share any information that we collect from or about you in accordance with our U.S.Consumer GLBA Privacy Notice. Information subject to our Privacy Notice is referred to as Non-Public Personal Information (“NPPI”).
A. Collection of Your Information.
The information we collect from you will vary depending on the product or service requested. We may ask for certain information such as your username, first and last name, birth date, telephone number, email address, mailing address, social security number, and other details related to your financial situation when you use our Service(s) and/or register for a True Link account. We may also collect information that you voluntarily provide to us when using the Service(s).
We may also collect and store information that you provide to us about other people. By submitting information about someone other than yourself, you represent that you are authorized to provide us with that person’s information for the purposes identified in this Privacy Policy and/or in connection with the Service(s).
We may also retain any messages you send through the Service(s), customer service correspondence (via telephone, chat, text, email or otherwise), and may collect information you provide in User Content you post to the Service(s).
Calls to True Link or to third-parties through True Link by you or to you may be recorded or monitored for quality assurance, customer service, training and/or risk management purposes.
B. Information that is Collected Automatically.
In addition to the information you provide to us directly, we may automatically collect information about your use of the Service(s), as described below.
Log file information. Log file information is automatically reported by your browser each time you access the Service(s). When you use our Service(s), our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring/ exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
Location information. When you use the Service, we may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device.
Cookies and other technology. Log file information is automatically reported by your browser each time you access the Service(s). When you use our Service(s), our servers may automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, operating system, platform type, the state or country from which you accessed the Service, software and hardware attributes (including Device ID), referring/ exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and the order of those pages, the data and time you used the Service and uploaded or posted content, error logs, files you download, and other such information.
- Cookies. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser or stores information or settings on your device. Cookies let us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.
- Clear gifs/web beacons. When you use the Service, we may employ web beacons (for example, clear gifs) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened, which links are clicked by recipients, and whether our emails are forwarded. The information allows for more accurate reporting and improvement of the Service.
- Web analytics services. We may use third-party Web analytics on our Service, such as Google Analytics. These service providers use the technology described above to help us analyze how users use the Service. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.
- Third-Party Ad Targeting. We sometimes use the above technologies for interest-based advertising, which may be based on your device or browser’s signals received across websites or applications, and over time. Please see the section titled “Tailored Advertising” to learn how you can opt out of these marketing methods and technologies.
We may use this information in a number of ways, including: (a) to remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) to provide custom, personalized content and information; (c) to provide our Service and monitor its effectiveness; (d) to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) to diagnose or fix technology problems; (f) to help you efficiently access your information after you sign in; and (g) to deliver advertising to you.
C. Information from Third-Party Sources. We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, when you open certain accounts at True Link, we are legally required to conduct due diligence about who you are. We may use third-party service providers who provide information about you in order for us to perform this due diligence. We may also acquire your information from third-parties.
2. Tailored Advertising.
We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other applications you use. Please refer to our U.S. Consumer GLBA Privacy Notice for more information on your rights pertaining to the sharing of NPPI. The ads may be based on various factors such as the content of the page you are visiting, information you enter, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
We may also allow other third-parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Service by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third-parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. If you receive tailored advertising on your computer through a web browser, you can learn more about such tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, by visiting the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.
Please note that to the extent advertising technology is integrated into the Service, you may still receive advertisements even if you opt out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
3. Do Not Track Signals and Similar Mechanisms.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.4. Use of Your Information.
We may use your information and/or combine any or all elements of your information for a number of purposes, including:To provide you with and manage the Service(s). We use your information to provide, develop, maintain and improve our Service(s) and the features and functionality of the Service(s). This may include customization and tailoring the Service(s) features according to the information that you provide.
To process and fulfill a request or other transaction submitted to us. We use your information to process or fulfill requests or transactions that you have requested.
To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt-out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). You may not opt-out of Service-related emails.
Provide personalized services, including content, ads, products or services. We may use the information we collect to provide personalized services and advertising to you. To learn more about your choices in connection with the use of your information for this purpose, please see the section above titled, “Tailored Advertising.”
Surveys, Offers, Sweepstakes. We may use your information to conduct surveys.
Marketing and Advertising. We may use your information to market and advertise our Services and the services of certain third parties we work with.
Research and Analytics. We may use your information for research and analytical purposes, for example, to identify trends and effectiveness of certain marketing campaigns we run.
Business Operations. We may use your information for certain operational purposes including, for example, perform audits and quality control.
To protect the rights of True Link and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of True Link, its employees or agents, or other users and to comply with applicable law.
With your consent. We may otherwise use your information with your consent or at your direction.
To aggregate/de-identify data. We may aggregate and/or de-identify information collected through the Service. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
5. Sharing of Your Information.
We may share the information we collect or receive from you in a variety of circumstances, including, but not limited to, as listed below.Card Administrators, Caretakers, Representative Payees, Trustees, Guardians, Conservators) and others who are similarly situated) (collectively, “Providers”). We may share your information with Providers for the purpose of providing the Service to you. Information you submit to a Provider through the service may be governed by the Provider’s privacy and security policies. For details of these policies, please consult the policies of the Providers directly.
Affiliates. We may share information between parent and subsidiary companies.
Service providers. We may share your personal information with third parties who work on behalf of, or with us such as vendors, processors, banks, brokers, agents and other representatives. Service providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics), helping us verify your identity, providing website hosting services (e.g., Amazon Web Services), providing additional financial services like ACH processing, securities trades, bank accounts, check processing, assisting with auditing functions, and helping us with marketing and related research activities.
Marketing partners. We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our Services on their site, or a True Link widget on their site, when you interact with that widget or click from their site to our Services.
Other parties when required by law or as necessary to protect our users and services. True Link may share your 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 reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) exercise or protect the rights, property, or personal safety of True Link, our Users or others.
Business transfers. We may buy or sell/divest/transfer True Link (including any shares in True Link), or any combination of its products, services, assets and/or businesses. Your information, which may include NPI, user names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of True Link.
Public Forums. Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If we remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. We are not responsible for the information that you choose to submit in your User Content.
Aggregated or de-identified information. We may also aggregate or de-identify data and may share that data without restriction.
Otherwise with your consent or at your direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
6. How We Store and Protect Your Information
Keeping Your Information Safe
True Link takes technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. True Link is not responsible for the functionality or security measures of any third-party or Provider. To protect your privacy and security, we take steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from True Link, at all times. Do not share your password with anyone and do limit your access to your computer or other devices by signing off after you have finished accessing your account.
For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission’s website at www.ftc.gov/news-events/media-resources/identity-theft-and-data-security.
To find out more about True Link's security measures, visit our security page
7. Your Choices About Your Information
A. Your Account Information and Settings If you would like to make any changes to your account information, please contact us at [email protected]. B. Email Promotions You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, transaction-related updates, changes/updates to features of the Service, and technical and security notices). If you have any questions, you can contact us directly at [email protected]. C. Opt-Out and Annual Notice. If you are an individual and have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer GLBA Privacy Notice. D. Choices Relating to Tailored Advertising Please see the section above titled, “Tailored Advertising,” for your choices relating to certain interest-based advertising.
8. How Long We Keep Your User Content
Following termination or deactivation of your account with us, True Link may retain your profile information and User Content for an additional period of time for backup, archival, or audit purposes. In certain circumstances, we are required by Federal and State regulations to store various information. In order to comply with those requirements, we may be unable to delete your information from our database until the legally required retention period expires.
9. Children’s Privacy
Our Services are not marketed to individuals under the age of 13. We also do not knowingly collect information from individuals under the age of 13 and request that such individuals not provide information to us.
10. Links to Other Web Sites and Services
We are not responsible for the practices employed by websites or services linked to or from the Service or to which you direct True Link to retrieve information, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. True Link is also not responsible for sites directing you to True Link. Our Terms of Service and Privacy Policy do not apply to those third-party sites either.
11. Your California Privacy Rights
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits Users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third-parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that were shared and the names and addresses of all third-parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit this form.The California Consumer Privacy Act (“CCPA”) also affords California residents certain rights over their personal information (subject to certain exceptions). Our CCPA Privacy Notice,which supplements this Privacy Policy, outlines those rights and explains how they may be exercised.
12. Complaints and How to Contact Us
To make a complaint about a privacy-related matter, or to request access to or correction of your personal information, or if you have any questions about this Privacy Policy or the Service, please contact us at [email protected] or by phone at 1-855-244-1209. We will review all complaints and determine whether the matter needs further investigation. In the event an investigation is conducted concerning your personal information, we will notify you of the outcome of the investigation.
13. Changes to Our Privacy Policy
True Link may modify or update this Privacy Policy from time to time to reflect changes in our business and practices, and so you should review this page periodically (www.TrueLinkfinancial.com/privacy-privacy/). If we make changes to this Privacy Policy, we will revise the “Last Updated” date at the top of this policy. If we make a material change to this Privacy Policy, we will notify you as required by law. Your continued use of the Service following any changes signifies your acceptance of our Privacy Policy as modified.California Consumer Privacy Act Notice for California Consumers GLBA Notice
PLEASE PRINT AND RETAIN A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS.
