Last updated: 1 January 2023

At ThinkingWealth, we respect and value the privacy of our Users and Clients. This Privacy Policy explains how we collect, use, disclose, and protect your Personal Information when you use our website (“Site”) and mobile application (“App”), collectively referred to as the “Services.” By using our Services, you agree to the terms outlined in this Privacy Policy.

Scope of this Privacy Policy

This Privacy Policy applies to information collected by ThinkingWealth through our Services. It does not apply to third-party websites, applications, or services that may be linked to or from our Services.

Personal Information We Collect

The categories of information we collect from Users differs from what we collect from those who qualify as Clients. Examples of instances when we collect Personal Information include:

1. When you answer questions on the Site or in the App to determine what kind of portfolio we might recommend if you were to become a Client,
2. When you register to open an account either as a User or a Client,
3. When you contact our client service organization with questions, or
4. When you agree to enter one of our Client Agreements.

Wherever ThinkingWealth collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms, such as our Website Terms of Use and/or Financial Planning Terms of Use.

Information We Collect from Users and Clients

We collect Personal Information from Users and Clients, including but not limited to:

1. Name, e-mail address, telephone number, zip code, Internet Protocol address, birth date;
2. Investable assets, income information, and other financial planning information about your household; and
3. Account numbers, routing numbers, and login credentials for the financial accounts you choose to link to our Services, any challenge and/or security questions associated with those linked accounts, and any information contained in those linked accounts.

Additional Information We Collect from Clients Only

In addition to the information described above, Clients provide us additional Personal Information, including but not limited to:

1. Your full legal name, contact information, birth date, National ID Number, citizenship, and marital status;
2. The full legal name, birth date, and National ID Number of any beneficiaries that Clients choose to list;
3. For purposes of identity verification, government-issued identification documents and self-portrait photographs (“selfie”); and
4. Investment objectives, approximate net worth, tax information, and other information required by federal and industry laws and regulations, such as employment information and stock restrictions (see our Client Agreements).

You are not required to provide these items to us to become a User, but Users who choose not to provide these items to us will not be able to become Clients.

How We Use Your Personal Information

We use your Personal Information to provide, maintain, and improve our Services, as well as to communicate with you about our Services, provide customer support, process transactions, and comply with legal obligations.

How We Share Your Personal Information

We may share your Personal Information with third parties, such as service providers and partners, to help us deliver our Services. We may also share your information to comply with legal obligations or to protect the rights and safety of our Users, Clients, and others.

How We Protect Your Personal Information

We implement reasonable security measures, including physical, electronic, and procedural safeguards, to protect your Personal Information. However, no method of transmission or storage is completely secure, and we cannot guarantee the absolute security of your Personal Information.

Accessing and Updating Your Personal Information

You can access and update your Personal Information by logging into your account on our Site or App. You can also contact us at support@thinkingwealth.ai to request access, correction, or deletion of your Personal Information. We will make reasonable efforts to comply with your request, subject to legal and regulatory requirements.

Retention of Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If you are a parent or guardian and believe that your child has provided us with Personal Information, please contact us at support@thinkingwealth.ai, and we will take steps to delete such information.

Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our Site and App, and updating the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us at:

ThinkingWealth

Email: support@thinkingwealth.ai

By using our Services, you acknowledge and agree that you have read, understood, and accepted the terms of this Privacy Policy.