Your privacy is very important to us and in this policy we outline how we collect, use, disclose, manage and safeguard your personal data when you use our services, browse our website or interact with us in other ways.
What Personal Data We Collect and Why
When you visit our website
With your consent, we may also collect the personal data you provide us when you choose to interact with our platform and website. This includes your name and email address. This information is used to contact you to provide the services you requested.
When you use our services as an advisor
If you are an advisor using our platform, you contact us or register for an account, we may collect the following types of personal data from you, with your consent where required:
- Contact information, such as full name and email address, so we can communicate with you;
- Occupation and title, as well as registration or licensing information for financial advisors so we can assess your credentials;
- Username and password, so you can create an account and provide you access to your account;
- Information you provide when you contact us, provide feedback, make a complaint or other inquiries; and
- Communications to allow you to communicate with your clients efficiently.
When you use our services as an advisor’s client
When you use our platform as a client of your advisor, we may collect personal data from you, such as your username and password that you use to log in to our platform. We may also collect personal data, with your consent where required, when you or your advisor provide your data directly into the platform, for example, when you contact us or when your advisor or your financial institution inputs, imports or automatically syncs your data into the platform.
How We Use The Personal Data We Collect
We only collect personal data that is necessary to provide our services. In serving you we may use your personal data to:
- Register your account with us and provide you with access to the platform;
- Manage advisors’ and clients accounts on the TelosTouch platform;
- Tailor the financial planning recommendations and presentation of information to clients and advisors;
- Facilitate interaction between advisors and their clients;
- Administer, troubleshoot, enhance and manage the website and the platform and tailor your experience while visiting the website and platform;
- Send communications and notifications, including updates on your subscription or account;
- With your permission, send promotional communications such as special offers or other promotions;
- Analyze the accuracy and effectiveness of the platform;
- Analyze and understand our users and their needs;
- Meet obligations as required by applicable laws; and
- Respond to inquiries, complaints and other communications from you.
How We May Share Your Personal Data
We do not sell, rent or disclose the personal data that we collect with third parties except in the following circumstances:
External Professionals and Experts: we may share your personal data, including financial information and financial documentation, with external professionals and experts (e.g., accountants, lawyers, etc.), selected by you in accordance with your instructions and only with your express consent.
Required by Law: We will disclose personal data in our custody when we believe that the disclosure is required by law, including to comply with a judicial proceeding, court order, or legal process served on us and when we receive a request from a regulatory or law enforcement authorities. When possible and allowed by law, we will inform you about the request for disclosure and we will only disclose personal data to law enforcement authorities upon demonstration of lawful authority.
Investigations: We will disclose personal data without your knowledge or consent where it is reasonable for the purposes of investigating a breach of an agreement or a contravention of the law that has been, is being or is about to be committed and it is reasonable to expect that disclosure with the knowledge or consent of the individual would compromise the investigation.
Fraud: We will disclose personal data where it is reasonable for the purposes of preventing, detecting or suppressing fraud and it is reasonable to expect that the disclosure with the knowledge or consent of the individual would compromise the ability to prevent, detect or suppress the fraud.
Business Transaction: We may disclose and share your personal data to explore and/or undertake a corporate transaction, including a merger, acquisition, amalgamation, IPO, reorganization or sale of the Company and/or the Platform. We will enter into an agreement that ensures that your personal data will be used and disclosed solely for the purposes related to the transaction, will be protected by security safeguards appropriate to the sensitivity of the information and will be retained only for as long as necessary.
How Do We Secure Your Personal Data
We are committed to safeguarding and to protecting the personal data we collect by security safeguards that meet industry standards for financial institutions and that are appropriate to the level of sensitivity of the data through (i) physical measures, such as secure areas; (ii) technical measures, such as encryption and secure servers; and (iii) organizational measures, such as access policies based on need-to-know and employee security through vetting and supervision. In particular, we employ the following measures:
- Security measures: our security controls follow SOC2 and ISO 27001 benchmarks to safeguard customer data.
- Encryption: all data is encrypted in transit and at rest using the industry standard algorithms.
- Backups: we retrieve, encrypt, and store daily backups of our production data storage systems;
- Monitoring: we perform regular monitoring and alerting of all production environments;
- High Availability: we leverage major cloud vendors to provide a reliable, fault-tolerant, and highly available solution to our customers.
- Employee access and training: all our employees receive training with respect to handling personal data and access to your data is provided on a need-to-know basis.
- Advisors: the advisors using our platform adhere to terms and conditions requiring them to protect the personal information they access and use through the platform.
Where We Store Your Personal Data
We store personal information on servers located in the jurisdiction where the advisor is located and stored with local Amazon Web Services and /or Microsoft servers.
How Long We Retain Your Personal Data
We only retain your personal data for as long as it is necessary for the purposes for which it was collected or as required by law.
What Are Your Privacy Rights
We maintain a well documented process for the creation, suspension, cancellation, modification and deletion of user accounts. Depending on your jurisdiction, you may have the following rights with respect to the personal data we collect and use:
Updating data: If you have created an account on our platform, you can update or make changes to your personal data by logging into your profile. If you do not have an account, you can contact us and we will update your personal data we have to ensure its accuracy.
Individual Access: If you make a request, we will let you know what personal data we have about you, what it is being used for, and with whom it has been shared. We will provide you with access to your personal data that is in our possession, subject to certain exceptions, such as information that refers to another individual’s personal information that we cannot sever, or information subject to solicitor-client privilege, or other legal restrictions that may prevent us from fulfilling your access request.
We will respond to your request within one month, free of charge, unless the volume or the complexity of the request requires a longer process. We will notify you if we require an extension and may charge a reasonable fee to cover administrative costs.
Rectification: If you notice any inaccuracies or wish to update any part of your personal information, we will rectify the information as necessary. We will provide rectification as soon as possible within one month. If we refuse the request, we will provide justification.
Withdraw consent: You may have the right to withdraw your consent to our use of your personal data. When we identify new opportunities that require processing your personal data for reasons other than those you have already consented for when we collected your information from you, we will seek your consent if required under applicable legislation. We will respect your option if you object to such new use or to withdraw your consent.
How You Can Opt-out of Receiving Promotional Communications
In the event you wish to unsubscribe from receiving promotional email communications from the Company, you may opt-out by:
- Removing yourself by clicking “unsubscribe” at the bottom of an email we send you, or
- Contacting us at: firstname.lastname@example.org.
If you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, such as notifications regarding your account or subscription, or as otherwise consistent with applicable law.
Last updated: August 2020