- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- DATA SECURITY
- DATA RETENTION
- YOUR RIGHTS
- WEB ACCESSIBILITY STATEMENT
- CALIFORNIA RESIDENT’S PRIVACY RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
At Lifeworks, our unique approach begins with your family’s values and vision, helping you to connect your financial assets—your life’s work—with what is most important to you. We believe that each client needs to have a well-documented strategic plan that serves as a roadmap for how they can live the life they want. We also believe in a simplified and transparent fee structure to get you there: No commissions. No hidden fees. No trading fees or account fees.
This Website is not intended for children and we do not knowingly collect data relating to children consistent with the U.S. Children’s Online Privacy Protection Act. If we learn that we have received information directly from a child under age 18 without the parent or legal guardian’s verified consent, we will use that information only to respond to the child/parent/guardian to inform the child that he or she may not use the Website.
Lifeworks Contact Information
Our contact details are:
Kurt Van Dyken
Email address: firstname.lastname@example.org
Postal address: 4095 Park East Court, Suite C Grand Rapids, MI 49546
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified.
- The data we or our service providers collect, use, store, and transfer from Users prior to becoming a Client includes:
- Identity Data includes first name and last name.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
- Usage Data includes information about how you use our Website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- In addition to the fields above, we also collect the following data in connection with providing services to you as a prospective Client, a Client, or if you provide this information to us:
- Identity Data includes Social Security Number, tax-payer identification number, driver’s license number, username or similar identifier, and date of birth.
- Financial Data includes payment card details, account numbers, routing numbers, and expiration dates.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Family Data includes your marital status and your beneficiaries’ full legal name and contact information.
- Personal Financial Data includes assets and liabilities, approximate net worth, income, expenses, investment activity, account information (including other institutions), investment experience and goals, custody, brokerage, and advisory agreements, other advisory agreements and legal documents, transactional information with us or others, account applications and forms, investment questionnaires and suitability documents, tax information and other regulatory information that may be necessary and required by federal and certain statutory laws such as employment information and stock restrictions, and other information needed to service account.
- The Data We Collect when Acting As a Client’s Authorized Agent information to us:
- Many of Lifeworks’s Users and Clients choose to aggregate information from accounts at other financial institutions onto their dashboard on our Site or in our App; in enabling this functionality, Lifeworks acts as an agent to retrieve the User or Client account information maintained by such third-party financial institutions with which the User or Client has a legally-binding customer relationship (“Account Information”).
- This Account Information may include account balances, transactions and holdings from the linked financial institutions. By choosing to use our Services to aggregate and analyze your Account Information, you expressly authorize and direct Lifeworks, on your behalf, to electronically retrieve all Account Information associated with the username and password that you use to link the account. Lifeworks does not store login credentials used to link Account Information. Rather, Lifeworks works with one or more third-party service providers to access and retrieve your Account Information.
- Any Account Information that Lifeworks receives is read-only and cannot be altered by Lifeworks or the third-party service provider we use to access and retrieve your Account Information. Any Account Information transmitted from a third-party financial service provider is transmitted via end-to-end encryption, and any credentials you provide are encrypted at rest.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- answer questions on the Website to determine what kind of portfolio we might recommend if you were to become a Client;
- create an account on our Website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- conduct a survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our Website, we may automatically collect data about your equipment, browsing actions and patterns.
Third-party sources. We may receive personal data about you from various third parties including our third-party service providers or custodian’s brokerage. We employ other companies and individuals to perform functions upon our behalf. Examples include storing and analyzing data, providing search results and links (including paid listings and links), providing customer service, and payment processing. They have access to user information needed to perform their functions, but may not use it for other purposes.
We may place “cookies” on the browser of your computer. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies may enhance the convenience and use of the Website. For example, the information provided through cookies may be used to recognize you as a previous user of the Website (so you do not have to enter your personal information every time), offer personalized information for your use, and otherwise facilitate your experience using the Website. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests; (c) where we need to comply with a legal or regulatory obligation. We use your data in the following ways:
- To manage our relationship with you;
- To enable you to complete a survey;
- To administer and protect our Website;
- To deliver relevant Website content to you;
- To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences;
- To make suggestions and recommendations to you about goods or services that may be of interest to you.
Marketing and Outreach
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You can manage the marketing and outreach we provide to you by opting out, which is described in the “Opting Out” section below.
You can ask us to stop sending you marketing messages at any time by replying to a marketing email with “unsubscribe” in the subject line, clicking “unsubscribe” in the marketing email itself, or by Contacting us at any time.
5. DISCLOSURES OF YOUR PERSONAL DATA
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties, including a custodian, who assist us in operating our site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. A custodian or custodian bank is a financial institution that holds clients’ securities for safekeeping to prevent them from being stolen or lost. The custodian may hold stocks or other assets in electronic or physical form. Those trusted third-party partners may:
- Provide you and members with various services
- Provide database maintenance and security
- Help us manage transactions
- Help us process and fulfill orders or requests
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. YOUR RIGHTS
Under certain circumstances, you may have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Right to withdraw consent to us processing your personal data.
9. WEB ACCESSIBILITY STATEMENT
Lifeworks is committed to making the Website’s content accessible and user friendly to everyone. If you are having difficulty viewing or navigating the content on this website, or notice any content, feature, or functionality that you believe is not fully accessible to people with disabilities, please call us at (616) 200-6512 or email us at email@example.com with “Assist with Access” in the subject line and provide a description of the specific feature you feel is not fully accessible or a suggestion for improvement.
10. CALIFORNIA RESIDENT’S PRIVACY RIGHTS
Lifeworks tracks its Users over time and across third-party websites to provide targeted advertising. Lifeworks responds to Do Not Track (DNT) signals where technically feasible. If you would like additional information regarding opting-out of tracking, please Contact Us.
California’s “Shine the Light” law permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org. This request may be made no more than once per calendar year.