Privacy Policy

Last updated February 15, 2020

We at VestServe respect your concerns about privacy. This Privacy Policy describes VestServe’s collection and use of personal information of users of our website at VestServe.com and our other services that display this Policy. This Policy describes the measures we take to safeguard the personal information, the parties with whom we may share the information, and the choices available regarding our use of the information.

TABLE OF CONTENTS

Collection of Personal Information

• Automated Information Collection [COOKIES]
• Third-Party Web Analytics Services
• Information from Other Sources

USE OF PERSONAL INFORMATION

DISCLOSURE OF PERSONAL INFORMATION

• Service Providers
• Business Transfers
• To Protect Our Interests

YOUR CHOICES

DATA TRANSFERS

SECURITY

LINKS AND THIRD-PARTY FUNCTIONALITY

CHILDREN’S PERSONAL INFORMATION

UPDATES TO THIS POLICY

CONTACTING US

COLLECTION OF PERSONAL INFORMATION
We collect personal information that our users provide to us in a variety of ways through our website and platform Services collectively referred to in this policy as the “Services”. These include the following:

• Login Credentials. You may be granted login credentials to access our Services.
• Communications. If you contact us by email, using the inquiry contact form on the Services or by postal mail, fax, or other means, we collect the personal information contained within, and associated with, your communication.

We collect personal information uploaded to our platform by VestServe customers who are paid subscribers of the Services for processing on their behalf. This is “Customer Data”. This information may include information about a client’s customers, such as name, email address and financial account data, in order to perform wealth management services for those customers via the Services. VestServe customers may electronically submit Customer Data to the Services ormay instruct third parties (including custodians) to do so. VestServe may access Customer Data except as prohibited by the license agreement between VestServe and the customer, or as otherwise prohibited by law.

Automated Information Collection
When you visit our Services, some information is collected automatically. For example, when you access our Services, we automatically collect your browser’s Internet Protocol (IP) address, your browser type, the nature of the device from which you are visiting the Services such as a personal computer or a mobile device, the identifier for any handheld or mobile device that you may be using, the website that you visited immediately prior to accessing any web-based Services, the actions you take on our Services, and the content, features, and activities in which you participate on our Services.

We may collect this information automatically using technologies such as standard server logs, cookies, and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use automatically-collected information to administer, operate, and improve our Services and to improve the effectiveness of our marketing. You can stop certain types of cookies from being downloaded to your computer by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. Our Services are not designed to respond to “do not track” signals received from browsers.

Third-Party Web Analytics Services
Through our Services, we may obtain personal information about your online activities over time and across third-party apps, websites, devices, and other online services. On our Services, we use third-party online analytics services, such as those of Google Analytics. The service providers that administer these analytics services use automated technologies to collect data (such as email addresses, IP addresses, cookies, and other device identifiers) to evaluate, for example, the use of our Services and to diagnose technical issues. To learn more about Google Analytics, please visit https://support.google.com/analytics/answer/6004245.

Information from Other Sources
We may receive personal information about you from third parties and may combine this information with other personal information we maintain about you.

USE OF PERSONAL INFORMATION
We use personal information about you to:

• provide services and information that you or your organization request;
• enhance, improve, operate, and maintain our Services, programs, website,
  apps, and other systems and features;
• prevent fraudulent use of our Services and other systems and features;
• prevent or take action against activities that are, or may be, in violation
  of our Terms of Use or applicable law;
• tailor content and other aspects of your experience on and in connection
  with the Services;
• maintain a record of our dealings with you; and
• perform other administrative activities.

We also may use your personal information for other purposes about which we will notify you when we request the information, and with your consent.

DISCLOSURE OF PERSONAL INFORMATION
Except as described in this Policy, we will not disclose your personal information to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Service Providers
We disclose personal information to third-party service providers such as those used for payment processing, data storage, and processing facilities that assist us in our work. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such personal information.

Business Transfers
Personal information about our users may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of VestServe assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

To Protect Our Interests
We also disclose personal information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of our Services, users of the Services or others.

YOUR CHOICES
We offer you certain choices in connection with the personal information we obtain about you. If we offer the ability to create user accounts or profiles on our Services, you may have the ability to access and update many categories of personal information that you provide to us by logging in to your account and accessing your account settings. If you wish to access or amend any other personal information we hold about you, you may contact us at privacy@VestServe.com. To the extent such personal information is Customer Data, we will use reasonable efforts to communicate your choices to your wealth management services provider.

If you request that we delete your account on any of our Services (via a user settings page, by email, or otherwise), we will do so within a reasonable period of time (or if otherwise required by law), but we may need to retain some of your personal information in order to satisfy our legal obligations in accordance with records retention obligations, or where we reasonably believe that we have a legitimate reason to do so.

You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails (current VestServe customers will continue to receive product alerts).

DATA TRANSFERS
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected.  Those countries may not have the same data protection laws as the country in which you initially provided the information.  When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Policy and will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries other than the one in which you provided the information.

If you are located in the European Economic Area (“EEA”) or Switzerland, with respect to transfers of personal information to the U.S., VestServe, Inc. is certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce, and the European Commission and Swiss Federal Data Protection and Information Commissioner, respectively, regarding the transfer of personal information from the EEA and Switzerland to the United States. Click here to view our EU/Swiss-U.S. Privacy Shield Privacy Policy.

SECURITY
VestServe uses reasonable security measures that are designed to protect personal information from accidental loss, disclosure, misuse, and destruction.

LINKS AND THIRD-PARTY FUNCTIONALITY
The Services may contain links to other websites, products, or services that we do not own or operate. For example, the Services may contain links to third-party sites, such as social networking services or custodial services. If you choose to visit or use any third-party sites or products or services available on or through such third-party sites, please be aware that this Policy will not apply to your activities or any information you share while using those third-party sites or any products or services available on or through such third-party sites. We are not responsible for the privacy practices of these third-party sites or any products or services on or through them. Additionally, please be aware that the Services may contain links to websites and services that we operate but that are governed by different privacy policies.

In addition, by using third-party services to log in to your VestServe account or access our Services, including through our application programming interface (API), you permit such third-party service to access and use all information related to your VestServe account that may be accessible to such third party service.

We encourage you to carefully review the privacy policies applicable to any website or service you visit other than the Services, or which you integrate into the Services using the API, before providing any personal information to them.

CHILDREN’S PERSONAL INFORMATION
The Services are designed for a general audience and are not directed to children under the age of 13.  The Services do not knowingly collect or solicit personal information from children under the age of 13.  If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information.  If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the Contacting Us section of this Privacy Policy below.

UPDATES TO THIS POLICY
We may occasionally update this Policy. When we do, we will also revise the “last updated” date at the beginning of the Policy. If we change this Policy in a manner that is materially less restrictive of our use or disclosure of your personal information, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any personal information that we collected from you prior to the date the change becomes effective. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose personal information.

CONTACTING US
To update your preferences, update or correct your information, or submit a request, or if you have any questions or comments about this Policy, please contact us using the following contact information:

VestServe, Inc.
14 Felton Street
Waltham, MA 02453
privacy @10.134.230.178