Last updated Mar 27, 2023
We Respect Your Privacy
Before you dig through the legalese, we would like to make one thing clear: We do not rent or sell your personal information.
Looking for something specific but don’t want to dig through the legalese?
Email us at email@example.com.
Last updated March 2023
- On the Sites.
- In email, text and other electronic messages between you and us that are related to the services that we are providing you.
- Through our mobile and desktop applications, which provide other means of communication and interaction between you and the Sites. We may combine the information collected on the Sites or through mobile application or other function with information collected from or about you in other contexts.
If you have any questions or concerns regarding this statement, you should contact us at firstname.lastname@example.org.
Information Collected by Us
The types of personal information that we collect and share depend on the product or service you use. We also may receive information about you that you authorize other parties to provide to us.
In addition, we may collect information provided by users who choose to open an investment advisory account with us, including but not limited to:
- Social Security numbers and financial account numbers;
- Account balances and transaction information;
- Identifiers and login information required by the provider of a third party financial account when you sync your account to our Sites, such as your username and password, or a security token;
- Income, tax, assets and employment information;
- Physical Address;
- Email Address;
- Marital Status;
- State or Federally-Issued Identification (Driver’s License/Passport);
- Information about your beneficiaries and/or trusted contacts;
- Salary; and
- Contact Information.
(collectively, “personal information”).
Also, if you sync your brokerage account(s) and/or bank account(s) to the Sites, you may be required to direct SigFig to retrieve your own information maintained online by third party financial institutions with which you have customer relationships, maintain accounts or engage in financial transactions (“Account Information”). We will then connect directly with your online financial service providers to access this Account Information and facilitate financial transactions that you initiate through the Sites. SigFig may also work with one or more third party financial service technology providers (“Service Provider”) to access and retrieve your Account Information. Your financial institution may provide us with information about you and your account to facilitate our ability to provide our services to you and to reduce the amount of data you need to enter. If you have linked external accounts and ultimately close your portfolio tracker and/or investment advisory account with SigFig, SigFig may continue to have access to the data from those external accounts unless action is expressly taken to terminate the connections. Some of this data may be maintained or stored by SigFig in line with its obligations under the federal securities laws and internal policies, which generally call for retention for a minimum of five (5) years. The period of retention may vary depending on regulatory requirements, when and if the individual has (and ultimately closes) an investment advisory account, and other circumstances that deem it necessary to retain the data.
We keep records of our services, which may include but are not limited to, records of the advice that we provide to you, your use of our services, and your communications to us about our services.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Sites and its contents to you;
- To provide you with information, products or services that you request from us;
- To market, personalize, develop and improve our products and services;
- To fulfill any other purpose for which you provide it;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to our Sites or any products or services we offer or provide through our Sites;
- To respond to your feedback or inquiries;
- In any other way we may describe when you provide the information; and
- For any other purposes with your consent.
Your personal and investment information is maintained by us in order to provide you with customized investment and other services and to fulfill our legal and regulatory requirements. In addition, for users who elected to open a SigFig investment advisory account, we use the collected information primarily to:
- Facilitate opening an account with an independent brokerage and custodial firm (“Broker-Dealer”);
- Creating, implementing and continuously managing your investment portfolio strategy aligned with the investment preferences specified by you;
- Provide the Broker-Dealer with information required to provide ongoing wealth management services to you; and
- Provide you with notifications related to your investment advisory account and our wealth management services.
Data that does not include personal information may be used for research purposes. For instance, we may compile data, excluding personal information, for purposes of demographic analysis and research.
We will send you service-related announcements on occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
As you navigate through and interact with the Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including browser-type related information, IP address, requested URL, referring URL, timestamp data, and other information to help us diagnose problems with our servers, administer the Sites, and otherwise provide the services to you. In addition, we may use this non-personal information to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Sites.
Partner Sites and Advertising
If you use the Partner Sites, we may share certain information about you with our Partners, such as “top ticker” data and watchlist holdings, which allow the partners to personalize your experience on the site or their mobile apps. We may also share aggregate data with Partners (without any of your personal information) to aid in monitoring the effectiveness of our product. Such data could include engagement and retention rates with our services, periodic usage metrics reports. Depending on the nature of the partnership (i.e. investment advisory account with a Partner), we may have access to or share other personal information with the Partner in the ways described above to provide the advisory or portfolio tracking services.
Please refer to our Partners’ privacy policies for more information about how they handle your data and information, including any personal information.
Unless we have your express permission, we will not share any personal information about you with any advertising companies or with the providers of the advertised goods and services, and these companies will not collect such information on our behalf. If you choose to use these separate goods and services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies.
Disclosure/Transfer of Information
- To our Partners, subsidiaries and affiliates;
- To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- With your consent;
- If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or the rights, property or safety of our customers or others.
We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to communicate an objection to such information sharing.
We have implemented measures and controls designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Our security measures include industry standard technology and equipment to help protect your personal information.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you are responsible for keeping this password confidential. We ask you to not share your password with anyone and please be sure to not choose a password which you have used on other sites.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your personal information transmitted to the Sites. Any transmission of personal information is at your own risk.
You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet or the circumvention of any privacy settings or security measures contained on the Sites, and you hereby release us from any and all claims arising out of or related to such interceptions of information or circumventions of our Sites.
Customer Preferences and Opt-out Choices
We may also use your information to contact you about our services that may be of interest to you. If you do not want us to use your information in this way, please provide notice to us through one of the following ways:
- Adjust your user preferences in your account profile; or
- To opt-out of receiving promotional or marketing communications from us at a specific address, you may:
- Use the unsubscribe instructions sent by us.
- Or Contact us by mail or phone at:
2443 Fillmore Street, #380-1512
San Francisco, CA 94115
- Note: It may take up to ten (10) business days to process your request post receipt of the request.
Accessing/Updating/Deleting Personal Information
Should you want to update your personal information, or to request assistance with accessing, correcting or deleting any personal information included in your account, please email email@example.com. We will try to respond to your request promptly, but no later than within thirty (30) days of receipt of such request. We may not accommodate a request to change information if we believe the change would violate any law or legal or regulatory requirement or cause the information to be incorrect. We cannot delete individual personal information for you, but can do a wipe of a user’s personal information upon request. Please note, however, that even if we close your account or wipe a user’s personal information, we may retain and use certain of your information as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.
Respecting Children’s Privacy
The Sites are not directed to children, and we do not knowingly solicit information from any child under the age of 13. If you are under the age of 13, do not use or provide any information on the Sites or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If a parent or guardian becomes aware that his or her child has provided us with personal information without his or her consent, he or she should contact us at firstname.lastname@example.org. Should a child whom we know to be under 13 send personal information to us, we will delete it as soon as possible..
Your Privacy Rights
In certain circumstances you may have the following rights in relation to the processing of your personal information:
- Access Request
To request a copy of the personal information we process in relation to you including: (i) the categories of personal information we collected about you and the categories of sources from which we collected the personal information; (ii) the business or commercial purpose for collecting the personal information about you; (iii) the categories of third parties to whom we disclosed personal information and the categories of personal information disclosed; and (iv) the specific pieces of personal information we collected about you.
- Deletion Request
To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
- Objection Request
To object to the processing of your personal information if: (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) we are processing your personal information for direct marketing purposes.
- Correction Request
To request that we update the personal information we process in relation to you, or to correct personal information that you think is incorrect or incomplete.
You may exercise these rights by contacting us in the manner established herein. To the extent permitted by applicable law or regulation, we reserve the right to charge an appropriate fee in connection with certain requests submitted by you.
We may need to request specific information from you to help us confirm your identify and ensure your right to access to the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.
We aim to respond to all legitimate requests within thirty (30) days of receipt of such requests. If we think it may take us longer (such as where your request is particularly complex or you have made a number of requests), we will attempt to notify you and keep you updated.
Frames and Partner Sites
2443 Fillmore Street #380-1512
San Francisco, CA 94115