Last Updated: August 14, 2023
Our Commitment to Privacy
We are committed to protecting the privacy of all personal information or data entrusted to us. We value the trust you have in us and are committed to maintaining your trust. Consistent with this commitment, we have developed Privacy Policies that describe the personal information that eMoney collects about you, how we use such information, and the choices that you can make regarding your information. Our privacy commitment is about more than complying with applicable privacy laws. It’s about doing the right thing and delivering on our purpose to help our Clients achieve financial security.
Our guiding data privacy principles demonstrate our commitment to manage personal information carefully and responsibly at eMoney:
- Data Minimization – We focus on business-to-business (“B2B”) data and limit our collection and processing of data to what is relevant and necessary to accomplish our business purposes. The majority of our products and services provide value through data analytics to identify connections and market advantages in high-level business data.
- Purpose – Using the personal information we collect to deliver essential intelligence and allowing our stakeholders to make informed decisions.
- Legal Compliance – In light of quickly evolving global privacy regulations, at eMoney we recognize privacy laws and privacy compliance is a core consideration.
Who We Are
What this Policy Covers
Our Collection of Personal Information
Our Use of Personal Information
Our Disclosure of Personal Information
Changes to This Policy
How to Contact Us
Who We Are
eMoney is a leading financial services technology company that provides comprehensive, scalable financial planning software, aggregation services and technical solutions to our clients. Our innovative technologies empower our clients to meet a broad range of needs for their customers. We also offer our mobile application called “Incentive” to 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 are collectively referred to as (the “Sites”). Together, our online software applications, technology services, Mobile App, and Sites are referred to as the “Services”.
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:
Personal Information You Provide to Us Directly:
- Contact Information: such as your name, address, phone number, and email address.
- Demographic Information: such as your date of birth.
- Account Information: such as your account username and password, and security questions as well as any information you place in the Vault.
- Transaction Information: such as payment information and purchase details.
- Event Information: such as your webinar, eMoney Summit, or other event enrollment information.
- Survey Information: such as your responses to User experience inquiries.
- Inquiry Information: such as the content of your email, text, or chat with us and, where applicable, your voice from calls with us.
- Prospective Employment Information: such as your resume, work history and references. For more information please visit here.
Personal Information Automatically Collected through our Sites or Services:
- Device Information: including your IP address, browser type, internet service provider, pages visited, operating system, user log and clickstream data, and time and date of visit.
- Cookie and Related Technology Data: including your usage and activity on our Sites and other interactions with our services using essential and non-essential cookies, web beacons and related data collection technologies. For example, our Sites use third-party tools (such as Hotjar, Google Analytics and other Google services), to support the operation and performance of our Site and to analyze your interactions and experiences with our Sites, including the features you engage with, how you navigate, and your click/touch, movement, scroll, and keystroke activity. You can find out how Google Analytics uses data here and how to opt out of Google Analytics here. For more information on how Google uses data when you use our websites, click here.We use Hotjar, a service provider, to help us understand and analyze how visitors use our services, and to improve the services. Hotjar may collect the following types of information from users of our Site:
- device IP Address
- device screen size
- device type (unique device identifiers)
- browser information, geographic location (country only)
- preferred language used to display our website
- Location Data: including your general geographic location based on your IP address or more precise location when accessing our services through a mobile device.
Personal Information Collected from Other Sources
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:
- Business Partners: Our business partners, such as our corporate affiliates, when your third-party service provider, collect personal information and often share some or all of this information with us. For example, in some instances we receive data feeds based on potential or integrated service offerings at the direction of the User. We also collect personal information from business partners involved in the administration of 401(k) plans, such as plan sponsors (employers), financial professionals, plan administrators, custodians, and recordkeepers. We may collect personal information from these parties in order to help financial professionals provide our Services to you. For example, once you elect to participate in your employer’s 401(k) plan, your employer will share your name, email, date of birth, and salary with your plan’s financial professional so he or she can input that information into our services and start creating your user account with us. We will then generate a unique invitation code for you so you can complete your onboarding process with us. Your plan sponsor (employer) also may provide us, through your financial professional, your 401(k) balance and deferral rate so your financial professional can use our services to recommend savings challenges to you.
- Service Providers/Contractors: Our service providers and contractors, such as payment processors and analytics providers, collect personal information through the Sites and Services, and often share some or all of this information with us. For example, we receive usage analysis data to improve and expand our services.
- Advisors: Advisors collect personal information directly from Customers and input that information into our Services. The information typically concerns Customers, their finances and their family, including name, address, phone number and financial information.
- Financial Institutions: at the direction of a Customer, financial institutions will share certain financial account information of that Customer with us. For example, when a Customer opts-in to link his or her investment account to our Services, that financial institution will share the account information with us so we can provide the Customer with an aggregated view of their financial information (this is called our “Connections” feature).
- Publicly Available Sources: you have registered for our Services, from time to time we may obtain additional personal information about you, such as address change information, from publicly available sources to keep our records current.
- We Collect Personal Information from Other Users: We may collect personal information about you from other Mobile App For example, a spouse may link a joint bank account to our Mobile App, which would share with us financial information about the other spouse. In addition, for individuals that share an Incentive account with you (e.g. a family account), we may collect information about you from those individuals.
- Social Media: If you choose to interact with us on social media, we may collect personal information about you from your social media account that you make public or share with We use personal information collected in connection with your social media account to communicate with you and better understand how you use our services.
- Your Employer: If the Services are provided from or through your employer, your employer may provide us with personal information in order for us to provide the Services to you and your employer.
Our Use of Personal Information
We use your personal information for the following commercial purposes and business purposes:
- Auditing: Auditing related to a current interaction with the Customer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use: provided that the personal information is not disclosed to another third party and is not used to build a profile about a Customer or otherwise alter an individual Customer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Providing Services: Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Research: Undertaking internal research for technological development and demonstration.
- Quality and Safety: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Specifically, we may use personal information we collect:
To Provide Products and Services
- Enable your activity within our Services and provide the Sites and Services to you generally, including to develop, enhance, and improve our Sites and Services and your experience.
- Register you for our Services and create your account with us.
- Enable you to use our Services, including to complete the onboarding process, receive coaching or training from us, or create financial plans.
- Deliver services you request, such as adding features or new functionality to the Sites and Services and providing customer service and technical support.
- Register you for webinars, events, and conferences.
- To enable single sign on (SSO) functionality and allow you to securely log in to several Services at once.
To Communicate With You
- Communicate with you and tell you about our current and future services, and offer you third party products and services we think you may find useful.
- Obtain your feedback in order to improve your experience with our Sites and Services, including through surveys we may send you on occasion (surveys are 100% optional and declining to complete a survey will not negatively impact your use of our Sites and Services).
- Communicate with you about and facilitate new contests, promotions and rewards, and upcoming events.
- Provide you with news about products and services offered by us and our business partners.
For Analytics and Personalization
- Provide you with a customized user experience.
- Display advertising that is tailored to your interests, including the marketing of our services. You also may opt out of receiving marketing communications from us at any time by following the instructions in the communication or emailing us as instructed below in the section titled, “Communications Preferences“).
- Link or combine with other information we get from third parties, to help understand your needs, customize our offerings to those needs, and provide you with better services.
For Security and Fraud and Prevention
- We use personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of eMoney and our users, customers, employees, or others.
- Enable SSO functionality and allow you to securely log in to several Services at once.
- Enhance the security of our Sites and Services and strengthen our defenses against cyber attacks and other unauthorized uses and disclosures
To Fulfill Our Legal Obligations
- We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
To Perform Core Business Functions
- Provide and maintain functionality of our Sites and Services.
- Review the usage of, improve the quality of and expand our services.
- Enforce and carry out contracts and agreements.
- Conduct internal operations pertaining to research, analytics, innovation, testing, monitoring, client communication, risk management, and administration.
- Perform routine backups of our data systems and prepare for disaster recovery.
- Coordinate with our business partners to allow them to market their products and services to you.
- Process and deliver contest entries and rewards.
- Conduct research and surveys used to measure our performance and improve our and our business partners’ products, services and User experience.
Our Disclosure of Personal Information
We disclose personal information in the following ways:
- Within eMoney: eMoney discloses personal information within eMoney and with our corporate affiliates for purposes and uses consistent with this Policy. For example, we may disclose your contact information to facilitate communication between you and an eMoney customer service representative. We share your personal information with various third parties so they can administer your 401(k) plan effectively, and so we can improve our services. For example, our Mobile App facilitates the relationship between you and the financial professional administering your 401(k) plan. As a result, the financial professional has access to most information you input into our services. Your financial professional will not see your transaction-level data, however, unless you affirmatively opt in to that level of Our Services also permit your financial 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.
- Third Party Business Partners: We may disclose personal information about Users with third parties, such as such as business partners, for research, academic, marketing and/or promotional purposes. We aim to conduct such research in a way that does not allow you or any other person to be identified. For example, we may share anonymized data regarding assets under management for our Advisors or demographic data that describes the average time spent using the services. We or our third-party partners may publicly report the statistical trends of the research or analysis, but only in a way that would not allow you or any other person to be identified.
- Service Providers/Contractors: We engage third-party service providers and contractors to perform functions and services on our behalf and under our instruction to make our Sites and Services available to you. For example, we may disclose transaction information to our payment processors to facilitate your transaction. We also may disclose additional personal information to application functionality providers to enable them to provide the necessary hardware, software, networking, storage, and other services we use to operate our services and maintain a high-quality experience for We may share your information with service providers that enable us to provide our Sites and Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics.
- Corporate Business Transactions: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company We disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Legal Obligations and Rights: We may disclose personal information:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to fulfill our contractual obligations;
- to detect, suppress, or prevent illegal activities, fraud, or misuse of data;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable laws.
- Consent: With your consent, or as directed by you or your authorized representative, we may disclose personal information about you to other third parties not described in this Policy.
- For example, the eMoney Wealth Management System exists to facilitate the relationship between you and your Advisor. As a result, the Advisor has access to your account information and anything that you elect to share with your Advisor.
- We also may share personal information with websites or services that you (or your Advisor on your behalf) have granted permission to access your eMoney account, such as financial institutions for purposes of facilitating our products and services.
- We also facilitate your sharing of information with your Alliance Partners where you have granted them access to your account.
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
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.
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 firstname.lastname@example.org 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.
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.
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.
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
eMoney Advisor, LLC Attn: Privacy Officer
Four Radnor Corporate Center
100 Matsonford Road, Suite 220
Radnor, PA 19087
Additional Information for California residents:
Click here for information regarding eMoney’s privacy disclosures specific to the California Consumer Protection Act (CCPA)