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Four Buckets Privacy Policy

 

Last updated on August 14, 2019

 

This Four Buckets Privacy Policy (the “policy”) describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. We refer to Four Buckets and our operating subsidiaries, Navigation Capital group, collectively as “Four Buckets”, “we” or “us”. Together with our Terms of Use Agreement and Terms of Use, this Privacy Policy governs your use of our platform and services.

Four Buckets is committed to the protection of our visitors, users and clients (also referred to as “you” or “your”) privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust. Let us start by saying unambiguously that we do not rent, sell or trade your Personal Information. Four Buckets’s core business is wealth management. This means that our objective is to win you over as a Client. We have no incentive to sell your information to others. In fact, Four Buckets is also a fiduciary for our Clients which means we are bound by law to act in our Client’s best interests.

 

How to Use this Privacy Policy

This policy describes if and how your Personal Information is shared and/or disclosed, how we collect and use other information and how we address other privacy matters – such as deletion of your Personal Information upon request, and opting-out of marketing communications. Lastly, we describe methods for contacting Four Buckets if you have privacy questions, comments or feedback.

Transparency is one of the best ways to earn your trust. The summary table below explains what information we collect from you and why based upon your relationship with us and as your relationship evolves with Four Buckets. This progression model is presented below.

 

How We Collect & Use Your Information

“Personal Information” means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (user id and passwords), social security number, government ID numbers and other information that can be used to identify you personally.

We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities. More information on this is provided below under the Visitors use case.

The following describes in further detail the information we collect at various stages of our relationship with you:

Visitors

When you visit any of our websites or download our apps, we consider you a Visitor. This section describes our privacy practices related to this use case.

What do we collect?Why do we collect it?Can you limit?
Four Buckets Cookies
  • To recognize you when you make a return visit and deliver overall a consistent experience
Most modern browsers allow you to delete or limit cookies.
Third-Party Tags and Cookies
  • To measure our marketing effectiveness
Most modern browsers allow you to delete or limit cookies, including third-party cookies however you may not be able to limit marketing tags entirely unless you do not visit our sites.
Internet Protocol (IP) Address
  • As part of the basic function of the internet
  • To measure who is visiting us and where they are from
The only way to avoid this is not visiting our sites.

Browser Metadata

Such as your browser type and version, operating system, language, etc.

  • As part of the basic function of the internet
  • To ensure we maintain a positive website experience for most used browsers
Browsers communicate this automatically however some third-party extensions may allow you to limit this.
What Visitor information do we share?

We share Visitor information in an anonymized format with our marketing partners for the purpose of measuring the effectiveness of our marketing campaigns.

 

Users

When you register, create a User Account on our Dashboard and begin using our services, we consider you a User. This section describes our privacy practices related to this use case. Keep in mind Users are also considered Visitors so this is information we collect in addition to what was described for Visitors.

What do we collect?Why do we collect it?Can you limit?
Email and Password
  • In order to establish your account and allow you secure access to it
  • Email you about service updates, maintenance activities, security notifications, weekly summaries and other account related information
  • Email you about service and/or product offerings, surveys and other marketing promotions
  • Allow our Support team to contact you if needed
No, that is required to have a functioning account. 
You can opt out of marketing emails, see the Opt-Out section.
Phone Number
  • In order to secure your account with our Multi-Factor Authentication
  • We may also, at your request or as appropriate for your situation and needs, contact you to recommend services and/or product offerings
  • Allow our Support or Security team to contact you if needed, at your request
No, we require this for security purposes. You can, however, signify us that you want to be placed on our Do Not Call list. See the Opt-Out section.

[Optional]

Financial Planning Information

Includes your age, retirement age, retirement plan information, risk tolerance, family information and other demographic or related information

  • To provide you our free Retirement Planner service and design your personalized retirement plan
  • To provide you with our Investment Checkup free service and perform an analysis of your investments (or other product features)
  • If qualified, provide you with a free financial consultation with one of our advisors
  • Conduct and publish anonymized aggregated research on personal finance trends
Yes, those are optional services which you are free to use or not use.

[Optional]

Financial Account Information

For third-party financial accounts you link – this includes your account credentials, passwords, security questions, transactions, balances, assets held, statements and other account information.

  • To provide you the holistic view of all of your finances in our Dashboard
  • To provide you our free financial planning tools
  • To allow background automatic refreshes of your data such that your Dashboard is always up to date
  • Conduct and publish anonymized aggregated research on personal finance trends
Yes, those are optional services which you are free to use or not use.
Product Use Information
  • Monitor and maintain system performance
  • Identify most popular features and inform new features development
  • Personalize your experience with Four Buckets
No, if you are a User we will collect this information
What User information do we share?

Personal Information

Sharing CategoryWhat do we share and why?
Our Service ProvidersAs most businesses, we use third-party service providers to deliver the services mentioned in this Privacy Policy. In doing so, we provide some of your data (including your Personal Information) to those third party service providers, on a need to know basis. Those service providers are required under contract with us to safeguard your information. Except where expressly set forth in this policy, our third-party service providers may only use your data to provide services to us or to improve their services.
Marketing PartnersWe also share users emails (or email hashes) and names in some cases with Marketing Partners working on our behalf and solely for marketing our services to you. We do not sell or allow your information to be used for any purpose other than to provide services to us. For example, if you participate in our referral program we will share your name and email with our referral management partner so you can be credited the referral bonus.
Security, Legal & Regulatory RequirementsWe also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, (v) if mandated by law or regulatory requirement, or (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
Anonymized Information

We may share anonymized information that is summarized or derived from information you provide to us as explained in the table below. Anonymized information is information that does not include any personally identifiable information.

Sharing CategoryWhat do we share and why?
Four Buckets ResearchFrom time to time Four Buckets performs relevant research on personal finance and related topics, utilizing anonymized and summarized insights from our users and clients.
Service ProvidersAs most businesses, we use third-party service providers to deliver the services mentioned in this Privacy Policy. In doing so, we authorize some Service Providers to use anonymized information to provide services to us or to improve their services generally. 

 

Clients

If you are opening an account with us and utilizing our fee-based wealth management service, we consider you a Client. Wealth management services are offered through Wealth Navigation Advisors, LLC. (WNA) Clients are also considered Users (and Visitors) so this section describes information that we collect in addition to what was described previously.

As part of our relationship with you as a Client, we will utilize the information we have on your financial dashboard in order to provide you with our holistic financial advice. We may also, at your request or as appropriate for your situation and needs, recommend third-party services to you.

What do we collect?Why do we collect it?Can you limit?

Detailed Account Information

  • Social Security Number
  • Mailing address
  • Tax planning information
  • Transferred securities information such as cost basis
  • Your beneficiaries
  • Contact information for investment accounts or banks you want to move funds from
  • Your investment objectives, if not previously collected
  • Other required personal information
  • Opening an account, on your behalf, with an independent securities brokerage trading and clearing custodian account or banking institution
  • Enabling us to fund of your accounts with your other investments assets or cash
  • Providing the independent broker or banking institution with ongoing information required to provide continuing services to you
  • Allowing us to perform tax analysis on the movement of assets, if applicable.
  • Designing, implementing and managing your investment portfolio strategy
  • Providing you with account statements, trade confirmations, tax information and other notifications related to the Wealth Management Service
  • Satisfying legal and regulatory requirements
Yes, becoming a client is entirely voluntary. If you opt to become a client, this information is required.
What Client information do we share?
Sharing CategoryWhat do we share and why?
Your brokerage account(s)As a client of Four Buckets, you will have a custodial brokerage account to hold your personal portfolio. Our custodial brokerage partner for our client’s accounts is Charles Schwab and we will share Detailed Account Information with them. You will have direct visibility, access, and interaction with Charles Schwab while you are a Four Buckets Client. The Privacy Policy of Charles Schwab is available here
Four Buckets does not share this information with other third-parties.
Marketing PartnersWe may share your name, mailing address and email address with our marketing partners to specifically exclude you from certain marketing campaigns. We contractually ensure that our partners do not use your information for any other purposes.

 

Additional Privacy Information and Your Privacy Rights and Resources

How to Request Deletion of the Personal Information We Collect

Four Buckets allows you to delete your account. We will retain information on deleted accounts as required for legal and security purposes.

Opt-out Information

If you request to be added to our Opt-out lists, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to Opt-out of the following:

  • Promotional or Product Notification emails
  • Advisor phone calls – notify your advisor at the time of the call to place you on the do not call list or reach out to the privacy team
  • Physical Mailings – send your request to our support team or privacy team to be added to Opt-out list

For opt-out requests, please find contact information under “Privacy Questions, Comments or Feedback?”below.

Email Records

Four Buckets keeps business records, including emails you send to us, for five (5) years to meet our regulatory compliance requirements. This includes any email you send to our privacy, security or support teams.

Data Residency

Our services and data are hosted in the United States and are intended for individuals located within the United States.

US State Residents Privacy Notices

To exercise any of your rights described below, please find contact information under “Privacy Questions, Comments or Feedback?” below.

Nevada Residents

We are providing you this notice under Nevada state law. You may be placed on our internal Do Not Call List by contacting us.

In addition to contacting us, Nevada residents can contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, in writing at 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; by calling (702) 486-3132; or by emailing: BCPINFO@ag.state.nv.us.

Vermont Residents

Under Vermont law, we will not share any Personal Information we collect about Vermont residents with third parties, unless the law allows.

California Residents

Residents of California have the right to request a disclosure describing what types of Personal Information (if any) we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year.

Protecting Children’s Privacy Online

Four Buckets is not directed to individuals under the age of thirteen (13), and those children should not provide Personal Information through our websites or applications. We do not knowingly collect information from children under 13 without parental consent. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website.

Modifications to our Privacy Policy

We change our privacy practices from time to time as the need arises. When we do, we will revise this Privacy Policy and we will post the revised document on our website at https://www.fourbuckets.com/privacy-policy.

When changes to this Privacy Policy are material, we will provide notice to Clients.

 

Privacy Questions, Comments or Feedback?

Please contact us*

Attention: Privacy Team

Four Buckets Corporation and its wholly owned subsidiaries

1148 W Legacy Crossing Blvd. Suite 300

Centerville, UT 84014

Call toll-free 801-335-8200

Visit www.fourbuckets.com

Email us at info@fourbuckets.com

*Note that the Privacy Team may not respond to automated requests or other requests that do not appear to be legitimate in nature.

 



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