AdvisorEngine
Privacy Policy

Collection of Information

Information you provide to us

To use the Platform, you must sign a licensing agreement and/or create an account(s).  In doing so, we collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, submit or post content through our Platform, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number including cell phone number, professional or employment-related information such as company name or representatives’ names, and any other information you choose to provide.

The AdvisorEngine Platform is not directed to children under the age of 16.  If a parent or guardian becomes aware that his or her child has provided us with personal information without your consent, please contact us at support@advisorengine.com.  If we become aware that a child under the age of 16 has provided us with personal information, we will take reasonable efforts to delete such personal information.

Information we collect automatically when you interact with us

When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including:

• Activity Information: We collect information about your activity on our Platform, such as data displayed.
• Transactional Information: When you make a purchase, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, see which areas and features of our Platform are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Platform and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy below and the Your Choices section below.

Information we collect from other sources

We obtain information from third-party sources in order to provide business services.  We do not sell the information we collect except as described herein. For example, we may collect information about you from identity verification, credit bureaus, advertising networks, data analytics providers, custodians, vendors you identify, and/or mailing list providers.  This information is required for the use of our services. Additionally, if you create or log into your AdvisorEngine account through a third-party platform (such as Facebook or Google), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform, however we do not collect this information and do no sell this information.

Information we derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP.

Use of Information

We use the information we collect to provide, maintain, administer and/or improve the Platform. We also use the information we collect to:

• Ensure proper functioning of AdvisorEngine and the Platform;
• Provide services, content, material and other information on the Platform;
• Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
• Personalize and improve your experience on our Platform;
• Identify and/or diagnose problems on or related to our Platform;
• Send you technical notices, security alerts, and support and administrative messages;
• Provide requested information, technical support and/or integrations such as an application programming interface or API;
• Respond to your comments and questions and provide customer service;
• Communicate with you about products, Platform, and events offered by AdvisorEngine and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our Platform;
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
• Personalize the advertisements you see when you use our Platform based on information provided by our advertising partners;
• Target prospective customers with our products or services (with your consent, where legally required);
• Detect, investigate, and prevent privacy and cyber security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of AdvisorEngine and others;
• Debug to identify and repair errors in our Platform;
• Comply with our legal and financial obligations;
• Carry out any other purpose described to you at the time the information was collected; and
• For other reasonable internal use or uses aligned with your relationship with us and the context in which we collected the information.

Sharing of Information

We share personal information in the following circumstances or as otherwise described in this policy:

• We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us or you, including without limitation, such as trade processing, data management, fraud prevention, customer service, AdvisorEngine merchandise, marketing and/or advertising.
• All authorized users listed on your account may view personal information stored in your account. A primary account holder may view personal information saved in sub-accounts to which it has authorized access.
• If you choose to use integrations we offer on our Platform, we share certain information with the integration partners.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of AdvisorEngine and its corporate affiliates, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may share personal information in connection with, or during negotiations concerning, merger, sale of company assets, financing, bankruptcy, business closure, or acquisition of all or a portion of our business by another company. Additionally, as part of such event, we may transfer or sell personal information to a third party. We will provide notice to you by email and/or a prominent notice on our Platform of any such sharing to a third party and any choices you may have regarding the sharing of your personal information.
• Personal information is shared between and among AdvisorEngine and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership (“corporate affiliates”). This information may be used to provide you with offers, services, or products that may be of interest to you and provide you with their products and services. Any such corporate affiliate may use your personal information only according to the terms of this Policy. If you are located in a jurisdiction where such sharing requires your permission, we will only share such information with your consent. If you decide you no longer wish to receive these promotional communications, please follow the instructions provided in Your Choices section below.
• We share personal information with your consent or at your direction.
• We also share aggregated or de-identified information that cannot reasonably be used to identify you.

Advertising and Analytics

AdvisorEngine may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Platform and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by AdvisorEngine and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Platform and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices (if you are in the US) or http://www.youronlinechoices.eu/ (if you are in the EU), or change your settings using the consent management tool on our Platform. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We may also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads. You may opt out of receiving marketing communications at any time through those platforms. Click here to manage your advertising preferences for NextRoll/Adroll which is the third party AdvisorEngine uses for its customized campaigns, and click here to manage your advertising preferences for Google Ads.

Transfer of Information to the United States and Other Countries

AdvisorEngine is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

Your Choices

Account Information

You may update or correct certain account information or deactivate your account at any time by logging into your account, emailing us at support@advisorengine.com, or calling us at 1-866-826-2731. If you wish to deactivate your account, please note that we may retain certain information as required by law or for our legitimate business purposes. If you decide you no longer wish to receive AdvisorEngine promotional communications, please click here.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Platform. For more information about cookies and how to disable them, see our Cookie Policy below.

Communications Preferences

You may opt out of receiving promotional emails from AdvisorEngine by following the instructions in those communications or by calling 1-866-826-2731. If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Your California Privacy Rights

California law, including the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83), afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information:  identifiers, commercial information, internet or other electronic network activity information, professional or employment-related information, and inferences. For details about the data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which AdvisorEngine has shared personal information with third parties in exchange for valuable consideration. AdvisorEngine does not “sell” personal information to advertise our products to you or otherwise.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing us at support@advisorengine.com or calling us at 1-866-826-2731. We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, account number and/or address. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at support@advisorengine.com or call us at 1-866-826-2731.

Do Not Track Signals

Our Services do not respond to “Do Not Track” signals communicated by your browser. We do not knowingly retain or sell tracking information collected about your online activity. For more information about Do Not Track, please visit www.allaboutdnt.com.

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When AdvisorEngine processes your personal data, AdvisorEngine will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and Platform you requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and Platform, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data associated with your account for as long as your account remains active. If you close your account, we will deactivate your account data within 30 days; otherwise, we will delete your account data after seven(7) years of inactivity. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at support@advisorengine.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Email: support@advisorengine.com

Toll-free telephone: 1-866-826-2731

Postal address: AdvisorEngine, 1616 E Millbrook Rd, Raleigh, NC 27609

Cookies Policy

Introduction and Scope of Policy

This AdvisorEngine Inc. Cookies Policy (“Policy”) applies to your interaction with AdvisorEngine Inc. or any of its subsidiaries (“AdvisorEngine”).

About "Cookies"

Cookies are pieces of data stored on your device. Browser cookies are assigned by a web server to the browser on your device. When you return to a site you have visited before, your browser gives this data back to the server. Mobile applications may also use cookies.

We use cookies and information gathered through their use to make your experience with AdvisorEngine and certain other websites (“Sites” or “Site”) richer and more personalized based on the products, services, or other interaction you have with us and other sites.

If you use multiple browsers or devices, information that we collect about you from one particular browser or device may be used to collect information on another browser or device. Information may also be transferred to a third-party information collection on behalf of AdvisorEngine. Please note that your choice to opt out on a particular browser or device will apply only to the collection and use of information from that particular browser or device. Opting out on a particular device will not opt you out of information collection on other devices, nor will it limit cross-device sharing on those other devices. If you use different browsers on a device or multiple devices, for each browser and device you wish to opt out, please opt out of each device and browser.

Industry standards are currently evolving, and we may not separately respond to or take any action with respect to a “do not track” configuration set in your internet browser.

Other parties that may collect information about your web browsing behavior when you use our Site are generally limited to service providers who may only use any information collected to provide services for us and not to provide services or advertising for any other party. Note, however, that we also provide certain widgets or tools on our sites that allow you to interact with third parties who provide these features, such as tools that allow web surfers to easily share information on another platform. At other times, information from a third party may be embedded on our Site, such as a map. These widgets, tools, and informational items often function through the use of third-party cookies utilized by the third-party site. As a result, these third parties may have access to information about your web browsing on the pages of our Site where these widgets, tools, or information are placed. You may wish to review information at third-party sites, where you have an account, to determine how these third parties treat data that they obtain through the use of cookies.

We also use cookies for purposes such as maintaining continuity during an online session; gathering data about the use of our Site; monitoring online promotions; and anti-fraud and information security purposes.

Do You Have to Accept Cookies?

If you do not want to accept AdvisorEngine’s marketing cookies, please select decline cookies. Also, you may be able to set your browser to reject browser cookies. If you set your browser options to disallow cookies, you will limit the functionality we can provide when you visit our Site. The latest versions of internet browsers provide cookie management tools, such as the ability to delete or reject cookies. We recommend that you refer to information supplied by browser providers for more specific information, including how to use these tools. Please note that declining or rejecting cookies could affect the availability and functionality of our Platform such as if you choose to reject all cookies, you cannot access your accounts online with AdvisorEngine.

Additional Cookies

Cookies is a term also used to describe other locally stored objects, such as cookies stored in an Adobe folder on your device. These cookies will not be deleted when you clear cookies from your browser. We may use this technology for purposes such as information security and fraud prevention. We do not use this technology for online behavioral advertising purposes. Please refer to information provided by Adobe for information on how to disable and control Flash objects. If you choose those options, you may limit the functionality we can provide when you visit our Site.

Additional Technologies

We may also use additional technologies such as pixel tags, web beacons, and clear GIFs, and may permit our third-party service providers to use these technologies. We use these technologies for purposes such as determining viewing and response rates and determining which offers to present to you on our own or on third-party sites.

Using Information

In addition to the uses described above, we use information for purposes as allowed by law such as: servicing; communicating with you; improving our Site, products, or services; legal compliance; risk control; information security; anti-fraud purposes; personalizing the presentation of our products and services to you; tracking website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites; and using read-receipt notifications in our email communications.

Sharing

We may share information with service providers with whom we work, such as service providers and companies that help us service you better. When permitted or required by law, we may share information with additional third parties for purposes including response to legal process. As applicable, please see our privacy policy for more information on how we may share information with affiliates and third parties.