Forward Financial Technology, LLC - Privacy Policy
Effective: 2/17/2017
Welcome to Forward Fintech! This Privacy Policy (the "Policy") forms an agreement between you, and if you are using this Site on behalf of an entity, that entity (in either case, "you") and Forward Financial Technology, LLC ("Forward Fintech," "us," "our," or "we").
This Policy describes the collection, use, disclosure, and processing of information collected online by our website located at www.forwardfintech.com (including any subdomains or mobile versions, the "Site(s)") and through our web-based financial services application and application programming interface (collectively, our "Web App"). We may refer to our Sites and Web App collectively as our "Service".
This Policy only addresses the collection, use, disclosure, and other processing of information we collect from you as part of our Service. Through your continued use of our Service, you acknowledge and agree to the practices described in this Policy.
This Policy is incorporated into our Terms Of Use, Services Agreement, and may be part of other Additional Agreements (as defined in our Terms of Use) which apply to your use of our Service. We may refer to capitalized terms that are defined in those Additional Agreements, and if undefined here, these capitalized will have the same meaning as in such Additional Agreement.
Please be aware that you may arrive at a third-party site or service when using our Service or a certain feature. This Policy does not apply to any use of those third-party sites. Please review any third parties' agreements to learn how they may collect, use and disclose your Personal Data.
Finally, if we receive your information from a third party as part of an Additional Agreement between Forward Fintech and a third party, any information we collect will be treated in accordance with this Policy unless expressly provided in that Additional Agreement. In the event this Policy conflicts with the terms of any Additional Agreement between you and Forward Fintech, the terms of the Additional Agreement control.
Our Service helps investment firms, broker-dealers, money managers, and similar entities (each a "Financial Firm") simplify the investment account creation and management process. To provide our Service, we collect certain information from users of our Service, typically financial advisors, brokers, consultants and planners which represent or work with or on behalf of a Financial Firm, and related account administrators ("Users"). These Users use our Service to collect and process certain information about individuals and entities ("Investors") relating to their account with a Financial Firm, as well as their investment priorities, goals, and other matters.
In this Policy, we may refer to "Personal Data" which means any information about an identifiable person, including that person's full name, address, online contact information, telephone number, any persistent identifier that can be used to recognize that person over time and across different services, precise geolocation information, and any other information about an individual that is linked to that information.
We may also refer to "Portfolio Information", which means the information we collect relating to an Investor's financial portfolio, such as that investor's investment goals, risk tolerance, investable assets, investment timetable and other similar information about an investor's portfolio.
We primarily collect and use information in the followings ways:
During the account registration process, we collect Personal Data about Users, such as the User's name, email, phone number, employer/Financial Firm name and address, and the name of any custodian or financial institution affiliated with such User or Financial Firm. User login information may be managed using a third-party 'single sign-on' application, and in such cases, Forward Fintech will not collect or store Users' usernames and passwords; however, we may receive certain information provided by that third party, such as the User's name and email address. Note, Users' Personal Data may also be provided to us by a User's employer or an account administrator.
We use the personal data we collect about Users during the registration process so that we can administer, manage and correspond with Users about the User's account, and to improve, personalize and deliver our Service. We may create and link to each user's account a summary of account activity, such as Investor accounts opened, monthly activity, and other similar information about that User or the Investors with whom they work. We may also add certain Users' email addresses to our company mailing list (such as Financial Firm account administrators) which informs our Users of upcoming product releases, notices, or other promotional material that may be of interest to them.
Our Service allows Users to provide information about Investors that will invest with a User and/or a Financial Firm. When a User uses our Service to process an Investor's Personal Data or financial information, we will collect the Personal Data required by the Financial Firm or User, such as the Investor's name, address, a spouse/dependent/beneficiary's name (if applicable,) and certain Portfolio Information (e.g. account type, amount invested, and planned contributions.) Further, if provided by the User, we may also collect a phone number, as well as more detailed Portfolio Information (such as asset allocations, historic performance, current fees, etc.) Please note, the information we collect may vary based on the specific data requested by each Financial Firm or User. In certain circumstances, we may, at the request of a User, also receive this information from a third party system or API that integrates with our Service.
We collect this information in order to complete common investment documents, to create an investor profile or analysis report, to generate a proposal for an Investor, and to otherwise provide our Services.
Please note, we may receive access to Personal Data or Portfolio Information as a result of a contract between an Investor and a third party, such as a Financial Firm, a financial custodian or trustee, or as a result of other contractual arrangements. Except as provided in an Additional Agreement, all information provided to Forward Fintech will be treated in accordance with this Policy. By entering an Investor's Personal Data and Portfolio Information into our Services, you represent that you have the necessary right and authority to provide this information to us.
On our Site, we request your name and email address if you contact us through our 'contact us' forms. We will use this and other information collected through the contact forms to correspond with you regarding your inquiry, or as otherwise necessary within the context of your request. We may also send you information relating to offers, promotions and other marketing communications if relevant to your request.
We may offer newsletters and other communications that provide information about our Service, company, partners and certain Financial Firms, or other information we think would be of interest to you. You may receive our newsletter when you sign up using the registration form on our Site, or because you are an existing customer or User of our Service. When you sign up for a newsletter or similar communication, we may collect your email address and any other Personal Data required by the online form. By providing this information, you consent to our collection of the Personal Data you provide to us and the use of that Personal Data in accordance with this Policy.
We may occasionally ask Users to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, or income level.) We may use this data to tailor your experience on our Services, and customize our offers and Service to you. We sometimes use contact data from our surveys to send you information and promotional material about our company and/or on behalf of our partners.
To make our Service more useful to you we (or our service provider(s)) may collect personal information and other data from you, including (without limitation) browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Like most internet services, we automatically gather this information and store it in log files each time you visit our website or access your account on our network.
Our Site may use cookies, web beacons and similar tracking technologies, such as Google Analytics. These technologies are widely used for security, to learn about and improve upon how users navigate a website or to enable certain features. Cookies are small data files that are transferred to your hard drive when your browser settings permit the acceptance of cookies. Similar technologies, such as web beacons or pixel tags function through the use of small files, such as a GIF or PNG, which are opened on a page or in an email. The request for these files from a server reveals certain information, such as your browser type, IP address, and other information. To learn more about cookies and similar tracking technologies, and how they can affect your privacy, visit allaboutcookies.org.
By tracking how and when you use our Site, these technologies help us determine which features and content on our Site are most important to our visitors. If you do not want information collected through the use of cookies, you can turn off cookies using your browser's settings menu; however, this may eliminate our ability to provide you with a personalized or user-friendly experience on our Site.
Please note, most modern browsers include a "do not track" feature that may help protect your privacy. However, our Site does not currently respond to your browser's do-not-track request.
To learn more about, or to opt-out of Google's analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.
Please note, certain portions of our Service may be hosted or provided by third parties. You may also visit other third party sites through links on our Site. These third parties are not bound by this Policy and may have privacy policies of their own governing the use and disclosure of Personal Data.
Our Service is designed to simplify data entry and processing for Investors, Users, and Financial Firms. Except as described below, or in accordance with any Additional Agreement or appropriate Investor/User consent, we do not share Personal Data or Portfolio Information with third parties.
As part of providing our Service, we will share Investors' Personal Data and Portfolio Information with the Investor's Financial Firm, and any Users authorized by that Financial Firm to access that Investor's information. In certain cases, Users may not be employed by a Financial Firm, and accordingly, certain information may be shared between a User and the third party Financial Firm with which that User has a relationship. Financial Firms may be able to view all Personal Data and Portfolio Information relating to Investors who have worked with that Financial Firm using our Service.
We may share Users' Personal Data and other account information and activity with a Financial Firm, or its service providers (e.g. IT departments or providers) to the extent necessary to provide our Services or upon the request of the Financial Firm, for example, for User monitoring or support purposes. The information we share typically includes the Financial Firm and/or User's name, phone and email, and any information relating to the Financial Firm's or User's financial custodian. We may also share any Personal Data and Portfolio Information we possess with third parties who provide services on our behalf or on behalf of a Financial Firm, such as hosting and analytics providers, electronic document systems, or similar service providers, and third-party customer management systems.
We further reserve the right to share any information we possess, including Personal Data and Portfolio Information, with our current or future affiliates, subsidiaries, parents, and partners who agree to abide by this Policy.
Finally, in extraordinary circumstances, we may share any personal or other information we possess when necessary or appropriate to: comply with the law; cooperate with law enforcement or national security requirements; respond to lawful requests; protect the rights of Forward Fintech, our Users, Financial Firms, Investors, and other third parties; or to investigate violations of or to enforce our Terms of Use. We will share any such information to the extent we believe that request requires. Legal requests include, for example, search warrants, subpoenas, and other court orders. We may also receive legal requests or orders from jurisdictions outside the United States, in which case such information may be transferred to the applicable country.
We will retain Personal Data about Users for as long as that User remains an active User, or for as long as we are required by law or relevant Financial Firm to retain such information, including a reasonable time thereafter.
We will retain Personal Data and Portfolio Information about Investors for so long as we are required to by law or the relevant Financial Firm and/or User, whichever is longer, and reserve the right to retain such information for a reasonable time thereafter.
Certain portions of our Service do not require you to provide Personal Data, however, our Service is designed to streamline the processing of documents that contain Personal Data. If you are an Investor and do not want us to process your personal information, please speak with your investment advisor or relevant Financial Firm.
We provide our Service on behalf of certain Financial Firms, and accordingly we may not provide a choice regarding sharing with certain third parties, including Financial Firms and Users that have a legitimate business need to access or use such information. Please note, if you do not wish for us to provide certain information to one or more of our service providers, we may be unable to complete a transaction you request. In addition, you may opt out of marketing communications from us. You can unsubscribe from all email newsletters or similar communications by clicking on the unsubscribe link provided in every email. You may opt out of all other information sharing with third parties for marketing purposes by contacting us at the address or email below.
If you are a User, you may access and modify your Personal Data and other account information using your account settings page. If that information is managed by a third party, such as a Financial Firm, you must speak with your account administrator to make changes. You may also access, change and modify information previously provided or collected by sending an email to us at [email protected] to initiate changes or modifications or to obtain a file for review. Note that we may require you to verify your identity prior to releasing any Personal Data or Portfolio Information to you.
You may close your User account only upon request from your account administrator or IT department (e.g. through your Financial Firm). If you are an account administrator, you may make modifications and close your account by contacting us using the information below. Further, you may request that your Personal Data be removed from all Forward Fintech systems, if permitted by your account administrator or Financial Firm (where applicable). This request must be made in writing to the address provided below. Note that if you request removal of your Personal Data you will no longer have access to any existing Forward Fintech account and will no longer be able to use our Service. Forward Fintech reserves the right to retain certain account information for its recordkeeping or compliance purposes.
California residents may request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may make one request each year by contacting us as set forth below.
We use reasonable security measures to protect any Personal Data held by Forward Fintech and we implement and review various physical, procedural, and technological safeguards that we believe will keep your Personal Data secure.
If you are accessing this Site from outside of the United States, you consent to the transfer of your information to the United States, and the processing, use, and sharing of your information in accordance with this Privacy Policy. If you are providing an Investor's Personal Data, you represent and warrant that you have the necessary right to transfer that information to the United States and have implemented any policies and procedures necessary to do so. We reserve the right to create and enforce geographic restrictions relating to access or use of our Site and service. You may not circumvent such controls, and if you choose to do so, you do so at your own risk. Forward Fintech will not be liable for any claims arising as a result of your transfer of Personal Data to the United States.
By providing us with any Personal Data, you expressly and unconditionally release and hold harmless Forward Fintech, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, Users, directors, officers, employees, and agents (collectively, the "Releasees") from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Data. In addition, while we take reasonable steps to prevent third-party companies from making unauthorized use of your Personal Data, we cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Data by those third parties.
This policy may change from time to time. We will post the most current version of this policy on our website with the effective date. Your continued use of the website means you consent to the terms of any new Policy.