Privacy Policy
Last revised: January 2023
This Privacy Policy describes the privacy practices of Facet Wealth, Inc. (“Facet Wealth,” “we”, “us” or “our”) and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.
California Notice at Collection: See the Information for California Residents section below for important information about your rights under applicable state privacy laws.
Personal Information We Collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Profile data, such as the username and password that you may set to establish an online account with us, date of birth, biographical details, photograph, interests, preferences, information about your participation in our promotions, or surveys, and any other information that you add to your account profile.
- Communications that we exchange with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content, such as profile pictures, images, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Financial information, such as your stated income, economic standing, financial account numbers or payment card information.
- Payment information needed to complete financial transactions, including payment card information or bank account number.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Data providers, such as information services and data licensors that may provide demographic and other information.
- Business and marketing partners, such as joint marketing partners and event co-sponsors, and partners who may refer you to Facet Wealth or otherwise provide your information to Facet Wealth.
Automatic data collection. In order to improve our service or track how clients come to our digital properties, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
- Location data when you authorize the Service to access your device’s location.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. Like many online services, we use the following technologies:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.
- Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
Session Replay Technologies. We use third-party services provided by Microsoft Clarity that employ software code to record users’ interactions with the Service in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Microsoft Clarity at https://privacy.microsoft.com/en-us/privacystatement.
Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service;
- facilitate your invitations to friends who you want to invite to join the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
- Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes.
- Direct marketing. We may send you Facet Wealth-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on our Service and other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across the Service, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your Choices section below.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
How We Share Your Personal Information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services, such as promotions. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we collaborate on joint activities (such as co-sponsors of contests and promotions), with whom we have entered into joint marketing relationships or other joint ventures, or who we think may offer you products or services that you may enjoy.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Facet Wealth or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your Choices
You have the following choices with respect to your personal information.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message. You may also reply STOP to the text message.
- Standard text messaging and data rates may apply
- Please text “HELP” for help
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Advertising choices. You can limit use of your information for interest-based advertising by:
- Browser settings. Blocking third-party cookies in your browser settings.
- Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google offers opt-out features that let you opt-out of use of your information for interest-based advertising:
- Google: https://adssettings.google.com/
- Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: https://opt out.aboutads.info.
- AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these opt-out settings on each device from which you wish to opt-out.
Do Not Track. 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” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
Other Sites and Services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International Data Transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Service from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to Contact Us
- Email: [email protected]
- Mail: Facet Wealth, Inc. 400 East Pratt Street, 8th Floor, Baltimore, MD 21202
- Phone: (443) 376-6222
Information For California Residents
This section applies only to California residents. It describes how we collect, use, disclose and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act but does not include data exempted from the scope of the CCPA.
Personal Information we collect from customers that have or used to have a financial product or service from us to be used primarily for personal, family or household purposes is subject to Facet Wealth’s Consumer Privacy Notice. If there is any conflict or inconsistency between this Privacy Policy and the Consumer Privacy Notice with respect to information we collect from customers that have or used to have a financial product or service from us to be used primarily for personal, family or household purposes, the Consumer Privacy Notice shall control to the extent of any such conflict or inconsistency with respect to such information.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.
- Information. You can request information about the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting, sharing and/or selling Personal Information; the categories of any Personal Information that we sold or disclosed for a business purpose; and the categories of any third parties with whom Personal Information was sold, shared or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
- Opt-out. You can opt-out of the sharing of your Personal Information for cross-contextual behavioral advertising purposes and/or from the sale of your Personal Information for monetary or other valuable consideration.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
How To Exercise Your Rights
- Right to information, access, correction, and deletion. You can request to exercise these rights by emailing us at [email protected] or call us toll free at (443) 376-6222.
- Right to opt-out of the “sale” or “sharing” of your Personal Information. You can request to opt-out of the “sharing” of your Personal Information by clicking the Do Not Sell or Share My Personal Information link in the footer of this webpage. Your request to opt-out will apply only to the browser and the device from which you submit the request.
- We do not otherwise “sell” Personal Information as defined by the CCPA. Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into your account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address used to make the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
- Sale and sharing of Personal Information. Our use of the online interest-based advertising services described above may constitute “sharing” of your Personal Information with our advertising partners from which you have the right to opt-out under the CCPA. You can request to opt-out of this “sharing” as detailed above. The categories of Personal Information shared include Identifiers and Internet or Network Information as described in the CCPA. As stated above, we do not otherwise “sell” Personal Information as defined by the CCPA. Although our Service is not intended for children under 16 years of age, we are required to inform you that we do not have actual knowledge that we have sold or shared the Personal Information of children under 16.
- Sensitive personal information. We do not use or disclose sensitive personal information (as that term is defined under CCPA) for purposes that California residents have a right to limit under the CCPA.
- Deidentified data. We do not to attempt to reidentify deidentified information that we derive from Personal Information except that we may do so to test whether our deidentification processes comply with applicable law.
- Retention. Our criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Privacy Policy, including complying with our legal obligations.
- Sources and purposes. We collect all categories of Personal Information from the sources, use them for the business purposes described in the Personal Information We Collect and How We Use Your Personal Information sections above, and disclose them for the business purposes described in the How We Share Your Personal Information section above.
Collection and disclosure. The chart below describes the Personal Information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose Personal Information for business purposes. The terms in the chart refer to the categories of information and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below. We may also disclose Personal Information to professional advisors, authorities and others, and business transferees as described above in the How We Share Your Personal Information section above.
Statutory category (Cal. Civ. Code § 1798.140) / Personal Information we collect | Categories of third parties to whom we disclose the Personal Information for a business purpose |
Identifiers
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California Customer Records (as defined in California Civil Code §1798.80)
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Commercial Information
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Financial Information
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Internet or Network Information
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Geolocation data
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Sensitive personal information
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Inferences May be derived from any of the above categories. |
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California Shine the Light. Under California’s Shine the Light law, California residents have the right to request the contact information of third parties with whom we have shared certain categories of your personal information for those third parties’ direct marketing purposes, as well as the categories of personal information shared for such purposes. Please note that these categories of personal information do not include the personal information covered under our Consumer Privacy Notice. If you are a California resident and would like to request this information, please contact us at [email protected].