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Privacy Policy
Last Updated: January 5, 2023
Last Updated: January 5, 2023
1. SCOPE
This Privacy Policy explains how ProNvest, Inc. (“ProNvest”, “we”, “us”, or “our”) collects, uses, and discloses information about you through its website, located at https://pronvest.com (the “Website”) and any other online services (“Services”), or when you otherwise interact with us. We are committed to the responsible management of consumer information and abide by all rules, both ethical and legal, with respect to the use of consumer information. Due to the nature of our business, the Services and Website are not directed to minors and minors are not eligible to use our Services. Except for beneficiary information, we do not collect, solicit, or maintain Personal Information from people we actually know are under 18 years of age. If we learn that a minor has provide us Personal Information without a parent’s or guardian’s consent, we will delete such information unless our regulatory obligations prevent us from doing so.
2. PERSONAL INFORMATION
“Personal Information” as used in this Privacy Policy meansinformation that allows someone to identify or contact you, and includes thefollowing categories of information:
· Full legal name
· Mailing address
· Telephone number
· Email address
· Date of Birth
· Account numbers
· Login credentials for certain financial accounts
· Transaction information and history
· Income, financial status, and financial planning information(including tax information, employment information, investment objectives, and net worth)
· Internet Protocol (IP) address
· User content
· Any other non-public information about you that is associated with or linked to any of the foregoing information
2.1 HOW WE COLLECT PERSONAL INFORMATION
We collect information from users and clients who access our Website or use our Services. The types of information collected from users versus clients will differ. For example, a Website user may provide certain limited Personal Information in order to evaluate our Services or access any free educational tools, whereas a client will provide more comprehensive Personal Information necessary to enable us to provide the Services. To access certain Services, you are required to create an account and provide your name, address, email address, password, birthday, social security number, as well as information about your retirement accounts and transactions, including but not limited to account balances, holdings, and inquiries. We collect and store information contained in your communications with us via email or other means. You can choose not to provide us with certain information, but this may limit the features of the Website or Services that you are able to use.
2.1.1 Authorized Representatives.
We may receive Personal Information about you from your authorized representatives such as your accountant, financial advisor, broker, or attorney. Any such information is considered Personal Information and is subject to the terms of this Privacy Policy.
2.1.2 Third Party Accounts.
We may require you to provide account credentials for your third-party accounts, including your 401(k)-provider account or any other accounts necessary for us to perform the Services. We will use such third-party account credentials solely to provide the Services requested by you. The Website allows you to connect with third party accounts through the Services. To provide us authorization to access your third-party account information, you must log in to the third-party account directly through the Services. To revoke our access to any third-party account, you must contact the third-party account provider.
2.1.3 Third Party Payment Processors.
In the absence of an integrated payment process, we may use a third-party payment processor such as Stripe to collect payment and billing information in order to process transactions. Data security, privacy, and handling of payments will be governed by the privacy policy and terms of use of the third-party payment processor.
2.2 HOW WE USE PERSONAL INFORMATION
We do not rent or sell your Personal Information to anyone. We may store and use your Personal Information for a variety of business purposes, such as to:
· Identify you as a user in our system
· Verify your identity
· Facilitate the creation of, secure, and administer your account
· Provide you with Services, including personalizing the Services for you and tailoring the features and content of the Services to you
· Provide you with customer support, respond to your requests, and troubleshoot and resolve problems
· Offer additional products and services to you, as well as those of a third party that we believe may interest you
· Verify your compliance with your obligations in any agreement between you and us
· Analyze and improve the quality of the Website and the Services
· Communicate with you about the Website and the Services
· We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.
2.3 HOW WE DISCLOSE PERSONAL INFORMATION
We will not share or disclose your Personal Information (whether you are a current or former user or client) to any nonaffiliated third parties except:
· Third parties to whom consent or instruct for us to send Personal Information, which may include 401(k) providers, authorized brokers, and authorized investment advisors
· Business partners with whom we jointly offer products or services
· Third parties, when necessary to effect the transactions and provide any services that you authorize
· Third parties who refer you to our Services
· Third party service providers who help us provide the Services or the Website
· Third parties assessing our compliance or to complete third-party financial, technical, and legal audits of our operations
· Third party service providers who assist us in marketing our products and services to you
· Our attorneys, accountants, and auditors
· Another company in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy
· If we believe in good faith that such disclosure is necessary to: (a) resolve disputes, investigate problems, or enforce our agreements with you; (b) detect, prevent, or address illegal activity on our Website or Services; (c) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we are authorized by you to disclose Personal Information without subpoenas or warrants served on us; (d) protect and defend our rights or property or the rights and property of you or third parties; (e) investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Website Terms of Use; or (f) prevent financial loss, protect your safety, protect the safety of others, including when there is an emergency involving potential harm or serious injury to people, or threats of such emergencies.
2.4 RIGHTS REGARDING YOUR PERSONAL INFORMATION
You have certain choices about how your Personal Information is used and disclosed. You can review and change some of your Personal Information by accessing your account via the Website. You may also to decline to provide us with Personal Information but declining to provide Personal Information may disqualify you from using the certain portions of the Website or Services. You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy.
You may request that we delete your Personal Information; however, clients and users cannot opt out of providing Personal Information and continue to use the Services. Certain Personal Information is necessary for us to provide the Website or Services and your deletion of such necessary information will interfere with or prohibit your use the Website or Services. Clients and users must close their account in order to opt out of further providing us with Personal Information. In some instances, we may be required (by law or otherwise) to retain this Personal Information and will comply with your deletion request only after we have fulfilled such requirements. Any deleted Personal Information is removed from our active database but may remain in our archives.
If, at any time, you do not wish to accept cookies from our Services for any of the purposes described in this Privacy Policy, then you can change your browser’s settings to disallow cookies, or to prompt you before accepting any cookies from websites you visit. If you do not accept cookies, you may not be able to use any or all portions of the Website or Services.
2.4.1 ProNvest Communications.
We will communicate with you primarily via email. You can opt out of receiving marketing emails by clicking “unsubscribe” at the bottom of any email or contacting us at info@pronvest.com.Please note that you cannot opt out of administrative communications such as regulatory, billing notifications, service notifications, or updates to our Terms of Use or Privacy Policy. You may elect to receive SMS communications from us. To opt out of SMS communications, reply STOP to any SMS you receive or contact us at info@pronvest.com. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
2.4.2 Third-Party Communications.
ProNvest may offer you the option to receive communications from third parties about products or services that may interest you. ProNvest will never share your information with these third parties without your prior consent. You can withdraw your consent to receive third-party communications at any time by modifying the settings in your account dashboard or, if such dashboard function is unavailable, by contacting us at support@pronvest.com.
2.5 SECURITY OF YOUR PERSONAL INFORMATION
We are committed to the security of your Personal Information and use reasonable administrative, technical, and physical safeguards to help protect your Personal Information from unauthorized access, use, alteration, or disclosure. While we make every reasonable effort to ensure the integrity and security of your Personal Information, we cannot ensure or warrant the security of any information you transmit to us.
3. ANONYMOUS INFORMATION
“Anonymous Information” as used in this Privacy Policy means information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with individual persons.
3.1 ANONYMOUS INFORMATION COLLECTED BY OUR SERVERS
We automatically gather certain information and store it in log files. Our servers are hosted by a third-party service provider and collect information from you, including but not limited to your:
· Browser type
· Operating system
· Internet Protocol (“IP”) address
· Geographic location
· Date and time stamp for your visit
· Clickstream data
· Referring and exit pages
This information is used or purposes such as: Website administration, trend analysis, and tailoring the Services to our users’ and clients’ needs.
3.1.1 Log Files.
We automatically gather certain information and store it in log files. This information includes:
· IP addresses
· Browser type
· Internet service provider (“ISP”)
· Referring and exit pages
· Operating system
· Date and time stamp
· Clickstream data
This information is used for purposes such as: Services administration, trend analysis, track users’ movements around the Services, and tailoring the Services to our users’ and clients’ needs.
3.1.2 Cookies.
We use cookies to collect information. “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Our cookies do not contain any personally identifying information, but they do enable us to provide features such as session validation. We may use these technologies to assess marketing strategies, ease website navigation, or any other use we deem appropriate for our business purposes. We may use different types of cookies, including session cookies, persistent cookies, or flash cookies. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features of the Website.
Third parties, such as Facebook, may use cookies and other storage technologies, to collect or receive your information to provide targeted ads. To opt out of the collection and use of information for ad targeting you can use http://www.aboutads.info/choices. You can also view your Facebook ads settings and update your preferences at any time.
3.1.3 Analytics.
We may partner with third party services and ad networks (such as Facebook), and tracking services (such as Google Analytics), to track and analyze both Personal Information and Anonymous Information from users of our Website. These third-party services may use Cookies to help track user behavior. Any use of these Cookies by third parties is not covered by our Privacy Policy. Some features that may be utilized include but are not limited to remarketing, audiences, demographic, or location information. We do not have access or control over these Cookies. For example, Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Website. This Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. We may also obtain Information from Partners, Business Associates and Unrelated Entities and combine that with Personal Information we collect about you.
3.2 HOW WE USE ANONYMOUS INFORMATION
Generally, we use Anonymous Information in statistical analysis to help us analyze patterns in the use of our Services. We may, through our use of Cookies, keep you logged into our Website, collect your clickstream data, tailor web content to you, and personalize your experience on the Website. We may also use your Anonymous Information to improve our internal operations, notify visitors of updates to our Website and Services, and software and customize the content and layout of the Website or Services. However, we reserve the right to use Anonymous Information for any purpose.
3.3 HOW WE DISCLOSE ANONYMOUS INFORMATION
We reserve the right to disclose Anonymous Information publicly without restriction.
4. INFORMATION COLLECTED AUTOMATICALLY
We automatically collect certain information when you use our Website or Services, which may include:
· Device identifiers
· IP address
· Web browser information
· Page view statistics
· Browsing history
· Usage information
· Transaction information (e.g. transaction amount, date and time of transaction)
· Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs)
· Location information (e.g. IP address, zip code)
· Other data (e.g. access times, hardware and software information)
When a person visits our Website, or opens one of our emails, a variety of information is automatically collected through standard web technologies. Some of this data is Anonymous Information. This data may be linked with your account and Personal Information to better assist our clients. Automatically collected information might include: the operating system on your computer, the type of Web browser you are using, your IP address, and the links you followed to enter and leave our Website.
5. INFORMATION THAT YOU DISCLOSE OR AUTHORIZE US TO DISCLOSE TO THIRD PARTIES
This Privacy Policy addresses only our use and disclosure of information we collect from or about you on the Website and Services. This Privacy Policy will not apply to any third party. If you disclose information to others or authorize us to disclose information to others in accordance with this Privacy Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
The Website may contain content or links to other websites. Any information you send to entities that are linked to our Website is out of our control and not covered by this Privacy Policy. We have no control over, do not review, and are not responsible for any privacy policies of or content displayed on such other websites. If you click such a link, you will leave our Website and another entity may collect Personal Information or Anonymous Information from you. The Website may also contain links to other websites controlled by us, but which operate under different privacy policies. Please review the privacy policy of any new website you visit.
6. CALIFORNIA RESIDENTS
California Consumer Privacy Act of 2018 (“CCPA”)
6.1 Data Requests:
California residents have the right to request and receive information regarding our data practices and the third parties to whom we have disclosed their Personal Information in the prior calendar year, including the type of information disclosed, the purpose for disclosure, and the specific pieces of Personal Information we have collected about you.
6.2 Data Deletion
California residents have the right to request that ProNvest delete all the Personal Information associated with them. ProNvest will respond to deletion requests within forty-five (45) days. ProNvest is not required to delete your Personal Information under certain circumstances, including circumstances where we are legally obligated to retain the information or if the information is needed to defend a legal claim. ProNvest will process all requests in accordance with its legal obligations under the CCPA, considering any exceptions. Please note that if you request deletion of your Personal Information, you may no longer have access to any or all portions of the Website or Services.
6.3 Submit A Request
You may submit your request for an electronic copy of Personal Information (by you or your verified authorized representative) or for deletion of your data to us via email at: info@pronvest.com.
7. DO NOT TRACK
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on the Services.
8. AMENDMENTS TO THIS PRIVACY POLICY
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on this page and we will change the “Last Updated” date located at the top of this page. You should consult this Privacy Policy regularly for any changes.
9. CONTACT US
If you have any questions or concerns regarding this Privacy Policy, or to report a security violation, please contact us via email at info@pronvest.com or at:
ProNvest, Inc.
1110 Market St., Suite 402
Chattanooga, TN 37402