PRIVACY STATEMENT

Information We Collect

The nature of the application (“Application”) is to collect and store sensitive information. We collect and store information from:

  • Our customers (“Advisors”)
  • Advisors’ clients (“Clients”)
  • Potential customers who sign up for trials of the Application (“Prospects”)
  • Affiliated third parties of the Advisors, Clients, and/or Prospects

Additionally, we collect and store:

  • Usage behavior of users
  • Aggregate information
  • System logs (e.g. error logs, system event logs, etc.)

This information can include a great deal of data including, but not limited to, names, addresses, contact information, social security numbers, account numbers, account values, files, etc.

Any and all information may be retained after a customer is no longer a customer.

Information We Disclose

We do not disclose information to non-affiliated third parties unless required by law (e.g. court order).

The Application does allow Advisors to initiate an information transfer to and from specific non-affiliate parties.  This transfer is controlled by the customer.  See the “Third Parties” section below for more details.

Third Parties

The Application allows users to transmit and receive information with various third parties.  We may collect and store the information being transmitted and/or received.  These third parties include:

  • Financial institutions (e.g. broker/dealers, investment houses, etc.)
  • Software vendors (e.g. financial services software in use by the Advisor)
  • Service vendors (e.g. account aggregation services partners)

Additionally, this information is stored in multiple locations by various third parties.  These third parties include:

  • Hosting providers (i.e. where the servers are)
  • Backup services

How We Protect Your Information

Access to information is limited to employees who must have access to the information stores to perform their duties in maintaining the application and the underlying data (e.g. database administrator).  Other non-technical staff members have access to a more limited set of data as a requirement of their job functions.

We maintain policies and procedures, encryption, physical, and programmatic controls to secure our users’ information.

Legal

Notwithstanding the information policies stated above, the right to store and disclose to third parties any information under the following circumstances is reserved: when the law permits it (such as, for example, to comply with laws or to respond to governmental authorities); to legal advisors; and to protect the rights, property, safety or security of Big Brain Works, Inc., Application users, or the public.

Big Brain Works, Inc. reserves the right to make changes to this Privacy Statement from time to time, which will be provided to you by posting the revised draft of the policy on Application’s website.  You will be able to determine when this Statement was last revised by checking the Last Revised date at the bottom of this document.

Last Updated: January 2016