eMONEY ADVISOR, LLC PRIVACY POLICY
Last Updated: January 2023
You can click on the following links to go directly to the corresponding sections of this Privacy Policy (this “Policy”). For California Disclosures please click here.
Who We Are
What this Policy Covers
Defined Terms
Our Collection of Personal Information
Our Use of Personal Information
Our Disclosure of Personal Information
Communication Preferences
Region-Specific Disclosures
Children’s Privacy
Third-Party Websites
Changes to This Policy
How to Contact Us
Your privacy is very important to us. This Policy explains how eMoney Advisor, LLC (“eMoney”, “we”, “us” or “our”) collects, uses, discloses, and protects personal information through our Sites and our mobile application, “Incentive”, in connection with our Services. This Policy also tells you about the rights and choices you have with respect to your personal information, and how you can reach us to get answers to your questions. Please note, our privacy practices are subject to the applicable laws of the places in which we operate. You will see additional region-specific terms that only apply to customers located in those geographic regions, or as required by applicable laws. We encourage you to read this Policy as well as the eMoney Terms of Use upon accessing our Services. Additionally, by using our Site, using Incentive, or by registering for any Services, you acknowledge that you have read and understand the terms of this Policy. If you do not agree with (i) this Policy, (ii) any revisions to this Policy, and/or (iii) any practices related to this Policy, or do not use, visit, register, or otherwise access the Sites, any Services, and content contained on the Sites or Services.
Who We Are
eMoney is a leading wealth management technology company that provides comprehensive, scalable financial planning software to financial firms and advisors. Our innovative technologies empower our clients to meet a broad range of planning needs for their customers. We also offer our mobile application called “Incentive” to employers, as well as financial professionals.
What this Policy Covers
This Policy covers the personal information we collect through the online software applications that we own and operate that link to this Policy. Our mobile application called “Incentive” (“Incentive”, or the “Mobile App”), and our websites, www.emoneyadvisor.com, and the informational site about Incentive available at www.getincentive.com (collectively, the “Sites”). Together our online software applications, Mobile App, and Sites are referred to as the “Services” or the “eMoney Wealth Management System”.
Defined Terms
An “Advisor” is a business customer using eMoney’s Wealth Management System (whether a financial advisor, financial institution, broker-dealer, registered investment advisor, third-party administrator, trust company, or family office customer) for the purpose of providing personal, family, or household financial planning services to Customers. “Customer” is an individual investor who is a customer of the Advisor, and who is given credentialed access to the Services by the Advisor.
When we use the term “User” in this Policy, we mean both Customers and representatives of the Advisor who have credentialed access the Services.
“Alliance Partners” are businesses or people that the Customer authorizes to view or access their personal information in the eMoney Wealth Management System, such as a banker, accountant, or attorney retained by the Customer.
When we use the term “aggregate,” “aggregated,” or “aggregation,” we mean a process undertaken at the direction of the Customer to gather information from various sources, such as financial institutions and financial accounts, to be consolidated into the eMoney Wealth Management System and/or the Mobile App. “Aggregated Customer Information” is the information that is gathered together into one location through this aggregation process, which still identifies the individual Customer. Note: This policy also refers to “Aggregated Consumer Information.” To avoid confusion, when we use the term, “Aggregated Consumer Information,” we are referring to data which has been ‘aggregated’ as defined by the California Consumer Privacy Act (“CCPA”), meaning the information relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.
When we use the term “personal information”, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you. This may include information such as an address, phone number, email address, a username or other online login information; and a financial account, as well as other information (e.g., employment-related or transactional information) when coupled with a person’s identifying information.
When we use the term “financial institution”, we mean a company engaged in the business of dealing with financial and monetary transactions such as deposits, loans, investments, and currency exchange.
When we use the term “financial professional”, we mean eMoney’s commercial customer such as licensed financial advisors, financial institutions, broker-dealers, home offices, registered investment advisors, third party administrators, trust companies, and family office clients.
When we use the term “process”, we mean access, use, store, convert, format, compile, display and/or distribute. When we refer to “user(s)” or “you” in this Notice, we are referring to individual consumers who receive access credentials to Incentive through participation in a 401(k) plan or from a financial professional.
Our Collection of Personal Information
The types of personal information we collect about you depends on how you interact with us and our Services. We may collect personal information directly from you and automatically when you interact with our Sites or Services. We may also collect personal information about you from other sources and third parties, even before our first direct interaction. The following are the categories and specific types of personal information that we collect:
For more information about cookies and related technologies, including on how to control your privacy settings, please read our Cookie Policy.
We sometimes also collect Account Information and Transaction Information from other sources which we may combine with personal information we collect from you. We receive such information from the following sources and third parties:
Our Use of Personal Information
We use your personal information for the following commercial purposes and business purposes:
Specifically, we may use personal information we collect:
Our Disclosure of Personal Information
professional to share statistical and anonymized data with your employer or other parties involved in administering your 401(k) plan. For more information, please see our Anonymized Data section below.
Anonymized and De-Identified Data
We may collect encoded or anonymized information or statistical data (such as IP addresses) (“Usage Data”) about a group or category of services, features or Users for research purposes. Usage Data helps us understand trends in usage of our services so that we can better consider new features or otherwise tailor our services. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our Advisor clients, affiliates, partners, and service providers, for various purposes, including to help us better understand our customers’ needs and improve our services as well as for advertising and marketing purposes.
We may, from time to time, collect de-identified data (“De-identified Data”) from our Users to prepare analyses, reports, and other materials regarding (i) how Users use the Services, (ii) the types and volume of assets managed within the Services, and (iii) other matters which may be useful to the financial advisor community. This De-identified Data may be combined with other Users’ De-identified Data for such purposes.
Controlling Your Personal Information
We process and store information on behalf of Users. At all times, Customers may choose whether or not to provide or disclose personal information to us. If you choose not to provide mandatory personal information, you may still visit parts of our Sites and/or our Services, but you may be unable to access certain options, programs, and services we typically offer. If you choose to share personal information with us, we strive to maintain accurate records of your personal information. To correct or delete personal information we store, Advisors may contact eMoney Customer Service by email, customerservice@emoneyadvisor.com, or by phone, 1-888-362-8482. For California Privacy Disclosure requests, please see visit the eMoney Advisor, LLC Privacy Policy Additional California Privacy Disclosures below.
Customers may correct or delete account aggregation information, by logging into the Services using their log-in credentials and make whatever changes and deletions they desire to the accounts they have established. All other information stored within the Services can only be changed or removed through the Customer’s Advisor. Customers should contact their Advisor if they want to change or remove information concerning them that is stored in the Services.
Communication Preferences
If you have opted-in to our marketing communications (or, where permitted by law, if you have provided us or we have obtained your contact information), we may send you email messages, direct mail offers, push notifications or other communications regarding products or services depending on the method of communication selected. If you would like to opt out of receiving communications from eMoney, please contact us at unsubscribe@emoneyadvisor.com or follow the unsubscribe instructions included in each marketing email. Please note that even if you opt out of receiving the foregoing communications, we may still contact you in response to any “Contact Us” requests as well as for administrative purposes.
Region-Specific Disclosures
We may be to provide different or additional disclosures relating to the processing of personal information about residents of certain countries and regions. Please click below to review additional disclosures applicable to you: If you are a resident of the State of California in the United States, click here for additional California privacy disclosures.
Please note that eMoney is subject to the Gramm-Leach-Bliley Act (“GLBA”), which regulates nonpublic personal information collected about individuals who receive personal, family, and household financial products or services from financial institutions. Several comprehensive state privacy laws in effect, or coming into effect in 2023, do not apply to entities subject to the GLBA, including the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Virginia Consumer Data Protection (“VCDPA”), and the Utah Consumer Privacy Act (“UCPA”). Because of this exemption, residents of Colorado, Connecticut, Virginia, and Utah are not eligible for additional rights granted by the CPA, CTDPA, VCDPA, and UCPA.
Children’s Privacy
Our Sites and Services are not directed to children under the age of 13. We do not intend to, or knowingly, collect or solicit personal information directly from children under the age of 13. If you are under the age of 13, do not use our Sites or Services or provide us with any personal information either directly or by other means. If a child under 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information. A child’s parent or guardian may provide the child’s information to us as part of a household.
Third-Party Websites
Our Sites and Services may contain links to third party websites and include embedded content that are hosted by such third parties. We are not responsible for the privacy practices or the content of these other websites. These third parties may use web measurement and customization technologies (such as cookies) in conjunction with the provision of this content or functionality. If you use a link to another website or view an embedded video, you should consult the privacy Policy for that site. We have no control over the information that is submitted to, or collected by, other websites and we are not responsible for the content of any linked site, or any link contained in a linked site, or any changes or updates to such sites, or any embedded video. This Policy applies solely to information collected by us or otherwise stored in the Services and our Site.
Changes to This Policy
We will update this Policy from time to time. When we make changes to this Policy, we will change the date at the beginning of this Policy to include the “Last Updated” date. If we make material changes to this Policy, we will notify you by email to your registered email address, by prominent posting on our Sites and Services (such as by placing a conspicuous announcement of the new Policy on the Sites or by presenting you with a web page containing an electronic copy of the Policy), or through other communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of our Sites or Services.
How to Contact Us
If you have any questions regarding this Policy, our Sites, the Services, or about eMoney’s privacy practices, please contact us by email at privacy@emoneyadvisor.com using the subject title of “Privacy Policy”, by phone at 1-888-362-8482 (and mention that you have a Privacy Policy issue related to the Services) or by mail to:
eMoney Advisor, LLC Attn: Privacy Officer
Four Radnor Corporate Center, Suite 300
100 Matsonford Road
Radnor, PA 19087
Last Updated: January 2023
These Additional California Privacy Disclosures (“CA Disclosures”) are provided pursuant to our obligations under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), and supplement the information contained in the eMoney Privacy Policy.
These Disclosures apply solely to our processing of personal information of individual California residents within the scope of CCPA. Any terms defined within the CCPA have the same meaning when utilizing within this CA Disclosures. The other provisions of the Policy continue to apply except as modified in these CA Disclosures.
These CA Disclosures do not apply to:
The majority of personal information that eMoney collects or maintains, including as a service provider to financial institutions, is covered by one or more of the exemptions described below (“CCPA Exemptions”). As a result, in most cases, eMoney may deny CCPA requests because the personal information at issue is subject to an exemption. For example, your CCPA request may be denied if:
You can find a list of the categories of personal information that we collect in the “Our Collection of Personal Information” section above. For details regarding the sources from which we obtain personal information, please see the “ Our Collection of Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “Our Use of Personal Information” section above.
In the last 12 months, we have collected and disclosed the following categories of personal information for a business purpose:
Category of Personal Information | Collected? | Disclosed for Business Purpose? |
Basic Identifiers: Name, postal address, phone
number, and email address, and similar identifiers |
Yes | Yes |
Personal Information Categories in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): including your contact information, identifiers, such as name, email address, mailing address, phone number, account id, and security/authentication information, financial account information, joint account holder and family information, credit and identity information relating to your account, account history relating to your account, and any other information you provide to us, including tax records, income level and signature | Yes | Yes |
Protected Classification Characteristics: including age, date of birth, gender, and sex. | Yes | Yes |
Commercial Information: including account history, investment history, purchases, transaction information, insurance coverage information, service profile information, interests, and feedback information, order details, order/product preferences, and credit information | Yes | Yes |
Biometric Information: Particular survey participants only | Yes | Yes |
Device Information and Other Unique Identifiers: including log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our Sites or Services) | Yes | Yes |
Geolocation Data: including your general geographic location based on your IP address or more precise location when accessing our Sites or Services through a mobile device | Yes | Yes |
Sensory Information: including voice recordings from calls to customer service | Yes | Yes |
Profession/Employment Information: including the business you represent your employer, department, income if provided, work history, and work title | Yes | Yes |
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99): including education history and any other educational information provided to us. | Yes | Yes |
Inferences Drawn from Personal Information Collected: including user preferences, customer characteristics, and behaviors. | Yes | Yes |
Sensitive Information: including social security, driver’s license, state identification card, or passport number; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; sexual orientation. | Yes | Yes |
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information (which includes the charts above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for your personal information, we consider applicable legal requirements, 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 we process your personal information for, and whether we can achieve those purposes through other means. For certain types of personal information, we will only maintain it for a limited duration. For example, for the Sensory Data we collect, we retain customer care call recordings for one (1) year. The table below provides the categories of PI and Sensitive PI we Sold or Shared with Third Parties for Cross-Context Behavioral Advertising.
Selling and Sharing of Personal Information
The table below provides the categories of PI and Sensitive PI we Sold or Shared with Third Parties for Cross-Context Behavioral Advertising.
Category of Personal Information | Sold? | Shared for Behavioral Advertising? | Purposes for Selling/Sharing | Categories of Third Parties to Whom Information Was Sold/Shared |
Basic Identifiers: Name, postal address, phone
number, and email address, and similar identifiers |
Yes | Yes | Commercial purposes, such as advertising | Advertisers and marketing partners, data analytics providers, and social media networks |
Personal Information Categories in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): including your contact information, identifiers, such as name, email address, mailing address, phone number, account id, and security/authentication information, financial account information, joint account holder and family information, credit and identity information relating to your account, account history relating to your account, and any other information you provide to us, including tax records, income level and signature | No | No | N/A | N/A |
Protected Classification Characteristics: including age, date of birth, gender, and sex. | No | No | N/A | N/A |
Commercial Information: including account history, investment history, purchases, transaction information, insurance coverage information, service profile information, interests, and feedback information, order details, order/product preferences, and credit information | Yes | Yes | Commercial purposes, such as advertising | Advertisers and marketing partners, data analytics providers, and social media networks |
Biometric Information | No | No | N/A | N/A |
Device Information and Other Unique Identifiers: including log file data (e.g., IP address, browser type, clickstream data) and cookies and related technology data (e.g., your usage and activity on our Sites or Services) | Yes | Yes | Commercial purposes, such as advertising | Advertisers and marketing partners, data analytics providers, and social media networks |
Geolocation Data: including your general geographic location based on your IP address or more precise location when accessing our Sites or Services through a mobile device | Yes | Yes | Commercial purposes, such as advertising | Advertisers and marketing partners, data analytics providers, and social media networks |
Sensory Information: including voice recordings from calls to customer service | No | No | N/A | N/A |
Profession/Employment Information: including the business you represent your employer, department, income if provided, work history, and work title | No | No | N/A | N/A |
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99): including education history and any other educational information provided to us. | No | No | N/A | N/A |
Inferences Drawn from Personal Information Collected: including user preferences, customer characteristics, and behaviors. | No | No | N/A | N/A |
Sensitive Information: including social security, driver’s license, state identification card, or passport number; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; sexual orientation. | No | No | N/A | N/A |
As described in the Our Collection of Personal Information section of our Privacy Policy, we collect personal information directly from you when you provide it to us, automatically when you visit our Sites and use our Services, from publicly available sources, and from service providers and other parties, including business partners, advisors, and financial institutions.
We collect personal information about you for the purposes described in the Our Use of Personal Information section of our Privacy Policy. For representatives of our clients, vendors, service providers and other parties, we also collect your personal information to maintain an ongoing relationship between us and the entity you represent and to contact you in connection with our relationship with the entity you represent.
As described in the Our Use of Personal Information section under the subtitle “Disclosures of Personal Information” of our Privacy Policy, we disclose personal information with a variety of parties. For representatives of our clients, vendors, service providers and other parties, we also disclose your personal information with the entity you represent.
Subject to certain limitations, California residents have the right to request access to (also referred to as the “right to know”) the categories and specific pieces of personal information we collect, use, and disclose; the right to request deletion of their personal information; the right to correction of their personal information; the right to opt out of any selling or sharing of personal information that may be occurring; the right to limit use and disclosure of their sensitive information; and the right to non-discrimination.
Right to Know
You have the right to request:
Right to Delete
You have the right to request the deletion or erasure of personal information we have collected about you. Following receipt of a verifiable request to delete, we will let you know what, if any, personal information we can delete from our records. We will also notify our service providers and contractors, and any third parties to which we transferred your information about your request to delete. If we cannot delete all of your personal information, we will let you know why.
Right to Correct
You have the right to request the correction of personal information we have collected about you. Upon receipt of a verifiable request to correct inaccurate personal information, we will take into account the nature of the personal information and the purposes for which we process it. We may require documentation from you in order to process your request where we have reliable documentation showing the accuracy of the information.
Right to Opt-Out
You have the right to direct us to not sell your personal information to third parties or share your personal information for cross-context behavioral advertising.
Some of the ways we use cookies for advertising and marketing are considered a “sale” or “sharing” under the CCPA. We provide California residents who use our Services a way to manage their cookie preferences based on categories of cookies. For more information about cookies and related technologies, including on how to control your privacy settings, please read our Cookie Policy here.
You can also opt-out of being tracked by these third parties by clicking “Do Not Sell My Personal Information” link at the bottom of our website and selecting your preferences, or by broadcasting the global privacy control (“GPC”) signal. Please note GPC signals are browser dependent and some browsers may not accept GPC signals unless a browser extension is used; please refer to your browser requirements to ensure you are transmitting the GPC signal accurately. Please note that your use of our website may still be tracked by eMoney and/or our service providers when necessary, such as to provide the website or security purposes.
We do not knowingly sell the personal information of consumers under 16 years of age.
Right to Limit
You have the right to direct us to limit the use and disclosure of your sensitive personal information. You may direct us to limit the use and disclosure of your Sensitive PI to uses/disclosures that are reasonably necessary to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. To limit our use of your Sensitive PI, please click here.
Right to Non-Discrimination
You have the right to be free from discrimination for exercising any of the rights described above. The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide access to certain of our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
To Exercise Your Right to Know, Delete, or Correct as a California Resident, please submit a request by:
We will need to verify your identity before processing your request. To verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know, right to deletion, and/or right to correct, particularly where we are unable to verify your identity.
You may designate an authorized agent to submit a request to know, delete, correct, request to opt-out of sale/share, and request to limit use of sensitive personal information on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; or (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
If you have been designated as an authorized agent to submit a request on behalf of another consumer, you must (1) download and complete this Authorized Agent Designation Form found here and have it signed by the consumer, and (2) attach the signed form when you submit a request to us at customerservice@emoneyadvisor.com.
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). We may disclose Personal Information to affiliates, which may use this information for all purposes outlined in our Privacy Policy. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their financial services, we are providing the following information for California residents who have provided us with their personal information during the creation of or during the course of an established services relationship that is primarily for personal, family, or household purposes (“Individual California Users”). Individual California Users must submit their requests to us either by email at privacy@emoneyadvisor.com or by mail at the address listed in the How to Contact Us section of the Privacy Policy and specify that you want a copy of your “Shine the Light” California Privacy Rights Policy.
We will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the date at the beginning of these CA Disclosures to include the “Last Updated” date. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our Sites or Services (such as by placing a conspicuous announcement of the new CA Disclosures on the Sites or by presenting you with a web page containing an electronic copy of the new CA Disclosures), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Your only remedy, if you do not accept the terms of these CA Disclosures.