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Privacy Policy


Introduction

Welcome to Active Allocator, Inc. We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Active Allocator, Inc. collects, including through Active Allocator, Inc. websites (www.ActiveAllocator.com) and our mobile apps for iOS and Android devices. It also explains why we collect the information and how we use it.

Privacy is important to Active Allocator, Inc. If you have any questions or if you believe that Active Allocator, Inc. has not adhered to this privacy policy, please send us a note at support@ActiveAllocator.com.

Summary

We collect device-related information, server log information, and other types of anonymous information when you visit Active Allocator, Inc. and when you become a customer of Active Allocator, Inc. Additionally, we collect personal information and financial information when you register and use your Active Allocator, Inc. account. We use your personal information to maintain your account, provide customer service, and enhance your customer experience. We use aggregated personal information and non-personal information to improve Active Allocator, Inc. and monitor and protect the security of our service.

We do not sell, rent, or trade your personal information with any third parties except as provided in this privacy policy, with your consent, or as required by law. In order to operate Active Allocator, Inc. and provide managed financial services and retirement plan services, we require certain personal information. If you are not comfortable providing personal information to Active Allocator, Inc., then our service won’t be useful to you and you will not be able to use our portal.

How You Accept This Policy

By using and continuing to use the Active Allocator, Inc. websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms of Service take precedence over any conflicting privacy policy provision.

Information We Collect

In order to provide a high quality service, Active Allocator, Inc. collects various types of information when you visit the service or sign-up as a customer. We collect various types of anonymous information about visitors to Active Allocator, Inc., such as device-related information (browser type, IP address) and server log information (date and time of day of your visit). We also collect information that you input into our website. We use this information to better understand our visitors and our business, to provide the services or information you request, and to enhance the Active Allocator, Inc. service.

When you choose to create an account with Active Allocator, Inc., we will also collect certain personal information, including your full legal name, email address, permanent address. You may choose not to provide this information, but you cannot become an Active Allocator, Inc. customer without providing it.

Beyond the registration process, we may collect various other types of personal information if you use the site. We collect your email address as part of our customer referral service. Further, we may collect personal information if you contact us or otherwise give it to us (e.g., in an email).

Cookies & Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.

We use these technologies in order to customize Active Allocator, Inc. and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Active Allocator, Inc. and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites in order to better customize our marketing and advertising campaigns. Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use this site. However, refusing to accept cookies or pixels will make the use of Active Allocator, Inc. more cumbersome and less accessible.

Analytics Services

We use analytics tools such as called “Google Analytics” (collectively referred to as “Analytics Services”) to collect information about the usage of this site. These analytics services collect information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We only use the information we get from these Analytics Services to improve this site. These Analytics Services only collect the IP address assigned to you on the date you visit this site, not your name or other identifying information. We do not combine the information collected through the use of these Analytics Services with personally identifiable information. The Analytics Services ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies.

You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here.

How We Use Your Personal Information

Active Allocator, Inc. uses personally identifiable and other collected information in a manner that is consistent with this privacy policy. We use your personal information to enhance your customer experience, operate and maintain your account in accordance with US law, investigate and understand how Active Allocator, Inc. is used, monitor and protect the security and integrity of Active Allocator, Inc., and better market and advertise Active Allocator, Inc.’s services. As part of this process, we may from time to time aggregate some of your personal information in certain data analysis, reports, or other interpretations of investment trends for both internal and external purposes. When aggregating personal information, we make sure that the information is not identifiable to any particular customer.

When We Share Your Information

We do not sell, rent, or trade your personal information with any third parties without your consent or as required by law. In order to provide financial services, we may share your personal information with third parties, such as consumer identification verification services and public accounting firms, for the purpose of serving you as a customer. In order to provide workplace services to employers or plan sponsors, such as retirement savings plan services and recordkeeping services, we may exchange any information received in connection with such services with the employer or plan sponsor or others they may authorize. We also may disclose some of the personal information we collect to service providers, companies that perform marketing and analytics services on our behalf, or to other financial institutions.

We may disclose personal information in response to service of legal process, such as a court order, summons, subpoenas, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, frontrunning or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Service or customer agreements. Information about our users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with Active Allocator Inc. or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity so receiving it. Last, we may disclose personal information in specific other cases with your consent.

Active Allocator, Inc. Mobile Apps

Our mobile applications (“apps”) allow you to access your accounts and make changes to your accounts, using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Children

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Active Allocator, Inc. and/or provided us with personally identifiable information, please contact us at support@ActiveAllocator.com. Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

How You Can Access Or Change Your Personal Information That We Have Collected

Once you have registered with Active Allocator, Inc., you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at support@ActiveAllocator.com. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years.

Protection Of Personal Information

Active Allocator, Inc. works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access, and we require third parties who perform services for Active Allocator, Inc. agree to keep your information confidential. Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Active Allocator, Inc. account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

How We Respond To Do Not Track Signals

Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Investors using certain modern browsers have the ability to activate a “Do Not Track” signal. Active Allocator, Inc. does not currently respond to the “Do Not Track” signal.

Changes To The Policy

We may modify this privacy policy over time by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If the changes are significant, Active Allocator Inc. will do our best to notify you via email or through a notification on the site. Please check the effective date below to determine if there have been any changes since you have last reviewed the Active Allocator, Inc. privacy policy.

Your Rights As A California Resident

Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@ActiveAllocator.com. Your request should specify your full name and the email address you used when submitting personal information to us.

Your Rights As A Vermont Resident

We do not share nonpublic personal financial information information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at support@ActiveAllocator.com. Please note, however, that we will not be able to provide you with services through Active Allocator, Inc. without the ability to share this financial information.

International Visitors

This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

Opt-out Notice

If you would like to opt-out of any of the above, please contact support@ActiveAllocator.com.

Questions

support@ActiveAllocator.com

EFFECTIVE DATE: January 31, 2016


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