PRIVACY POLICY

LAST UPDATED: 04 April 2016

1. Introduction

1.1 TrackWealth is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust. We NEVER rent, sell or trade your personal information to anyone. Ever. This Privacy & Security Statement describes the specific policies and procedures we use to collect, utilize, and disclose and share with others user, consultation recipient, and/or client information provided to us through our marketing partners; the use of our web sites and applications; and other communications with representatives of Personal Capital Corporation and our wholly-owned subsidiaries. We refer to Planar Investments Private Limited and TrackWealth collectively as "TrackWealth" or "we" or "us". We refer to those who visit our website and those who use our web and mobile applications collectively as “users”. Together with our Terms of Use, this Privacy & Security Statement governs your use of our services.
1.2 ​By using our website, you consent to our use of your personal information in accordance with the terms of this policy.

2. Collecting your personal information

2.1 ​We may collect, store and use the following kinds of personal information about you:
2.1.1 Information about your computer and about your visits to and use of this website ​​(including your IP address, geographical location, browser type and version, operating ​​system, referral source, length of visit, page views and website navigation paths);
2.1.2 ​Information that you provide to us when registering with our website (Email is the ​​only mandatory field required to register. Other optional fields include your name, email ​​address, phone number, citizenship, location);
2.1.3 ​Information that you provide when completing your profile on our website (including ​your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, ​educational details and employment details);
2.1.4 ​Information that you provide to us for the purpose of subscribing to our email ​​notifications and/or newsletters (including your name and email address);
2.1.5 ​Information that you provide to us when using the services on our website, or that is ​generated in the course of the use of those services (including the timing, frequency and ​pattern of service use);
2.1.6 ​Information relating to any contact you initiate on any product/ services or any other ​transactions that you enter into through our website or outside it;
2.1.7 ​Information that you post to our website (including your chosen public display name, ​user name, your profile pictures and the content of your posts);
2.1.8 ​Information contained in or relating to any communications that you send to us or ​send through our website (including the communication content and meta data associated ​with the communication);
2.1.9 ​Information that you provide to us by using either Facebook, Linkedin or Google ​​social plugin login, thereby giving access to personal detail information as per the individual ​policies of each of these third party websites. This information is not limited to your ​​personal details, but could also include information on your contacts or friends; and
2.1.10 ​Information from or about the computer, mobile phone, or other devices you use the ​website, including when multiple users log in from the same device. This may include ​​network and communication information, such as your IP address or mobile phone number, ​and other information about things like your internet service, operating system, location, the ​type (including identifiers) of the device or browser you use, or the pages you visit.

3. Using your personal information

3.1 The personal information you submit to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
3.2.1 ​personalise our website for you;
3.2.2 ​enable your use of the services available on our website;
3.2.3 ​supply to you services purchased through our website;
3.2.4 ​send you marketing commercial communications (if you have requested them) and ​you can at any time unsubscribe from marketing communications);
3.2.5 send you email notifications that you have specifically requested;
3.2.6 ​send your contact information to third parties you have requested to connect with;
3.2.7 ​send you our email newsletter, if you have requested it (you can inform us at any ​​time if you no longer require the newsletter);
3.2.8 ​send you marketing communications relating to our business (or the businesses of ​carefully-selected third parties) which we think may be of interest to you, by post or, where ​you have specifically agreed to this, by email or similar technology (you can inform us at ​​any time if you no longer require marketing communications);
3.2.9 provide third parties with statistical information about our users (but those third ​​parties will not be able to identify any individual user from that information);
3.2.10 ​deal with enquiries and complaints made by or about you relating to our website;
3.2.11 ​keep our website secure and prevent fraud;
3.2.12 ​verify compliance with the terms and conditions governing the use of our website;
3.2.13 publish your personal information on the website (if, and to the extent, you request ​us to do so).
3.4 ​Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 ​We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

4. DISCLOSING PERSONAL INFORMATION

Except as set forth in this Privacy & Security Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. And we will NEVER sell, rent or trade your Personal Information.

We may share your Personal Information:

4.1 To conduct everyday business :If you have registered to use our dashboard to aggregate your banking and other financial accounts, we will transmit your account credentials from the personal data vault on your device to those 3rd party institutions where you hold accounts to gather and maintain your account balances, transactions and holdings used to provide our services. (Read more about our secure handling of your credentials);
4.2 We may share your Personal Information with our wholly-owned subsidiaries for everyday business purposes,i.e. to provide financial insights and advice and improving your user experience.
4.3 We may disclose your personal information:
4.3.1 ​To the extent that we are required to do so by law;
4.3.2 ​In connection with any ongoing or prospective legal proceedings;
4.3.3 ​In order to establish, exercise or defend our legal rights (including providing ​​information to others for the purposes of fraud prevention and reducing credit risk);

5. OTHER DATA COLLECTION AND USE

We collect and utilize Other Information to optimize, secure and simplify your experience with us. Your Other Information is not disclosed or shared outside of TrackWealth.

5.1 Your Browser or Device : Certain information is collected by most browsers or applications, such as your “user agent string”, to help us determine your computing device type, operating system version and Internet browser type and version. We use this information to ensure that our web sites function properly and for security purposes.
5.2 Your Cookies : Cookies are pieces of information stored directly on the computing device you are using. Cookies we use do not contain or capture Personal Information. Cookies allow us to collect information such as your browser type, time spent on our web sites and which of our pages you visited. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience and to recognize authorized devices to secure your use of our services. We also gather statistical information about web site usage in order to continually improve the design and functionality and to assist us with resolving technical support questions. Additionally, we use cookies on our web sites and the sites on which we advertise to track advertising performance and to collect aggregate data on web page viewing and mobile app usage. Cookies may be connected to third-party companies or websites. The privacy practices of the companies placing such cookies are governed by the privacy policies of such third-party companies or websites. As an example, Google Analytics measures the performance of advertisements by placing cookies on your computer when you click on an advertisement. When you visit the website which you clicked on, you will have cookies placed on your computer. As a result, we and Google will be able to tell that you saw the ad delivered by Google. The privacy practices pertaining to these cookies are governed by our Privacy Statement and Google’s Privacy Policy. Cookies are not used to collect or disseminate any Personal Information. You can manage the placement of cookies on your computer through the features found in most Internet browsers. You can also delete cookies that have already been placed on your computer. Consult the "Help" function of your browser to explore your options.
5.3 ​Pixels Tags: TrackWealth deploys Pixel Tags as pixel images (GIFs), used to track your access to web site pages, and HTML-formatted email messages. We use pixel tags to measure the effectiveness of our communications, the success of our marketing campaigns, compile statistics about usage and response rates, and to assist us in resolving client questions about the use of our services.
5.4 ​​Your IP Address: Your IP Address is a number assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged whenever you visit our web sites or applications, along with the page(s) that were visited. We use IP Addresses, individually and collectively, for purposes such as calculating usage levels, helping diagnose technical problems and supporting our web sites and applications. Additionally, we use your IP Address to assist in fraud detection and authentication to better protect your security.

6. ADDITIONAL PRIVACY AND SECURITY INFORMATION

To protect Personal Information from unauthorized access and use, we use security measures that comply with relevant laws and regulations. Beyond this Privacy & Security Statement, we provide additional security measures, such as:

6.1 Bank Level Security: TrackWealth is powered using technologies and practices that many banks and other financial institutions use to protect customer information, such as SSL encryption for data in transit and AES encryption for sensitive data at rest.
6.2 We do not store your financial institution credentials in our systems or in our applications. These institution credentials are stored on the device you access TrackWealth from, in an encrypted data vault named as Personal Data Vault(“PDV”) .Our account aggregation service including the PDV is provided by an industry-leading third-party account aggregation service. That service employs comprehensive financial data security standards and is subject to ongoing multi-agency financial institution regulatory examinations.
6.3 ​No Money Movement: While using the dashboard app, you can only view financial account balances and transactions. You cannot transfer money between accounts, authorize spending or move money, safeguarding you from unauthorized money transfers from your financial accounts.
Account Monitoring: Our dashboard app allows you to monitor all your transactions for accounts linked to our dashboard, providing you with a comprehensive view of all account activities.
6.4 ​​Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.5 ​​​Reviewing and Updating your Personally Identifiable Information : You can view and update the profile and account information we collect for you by going to the “settings” function in our website and in our app. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.
6.6 ​​​​Email Marketing Opt-out : When we communicate our own marketing offers to you, these communications are SPAM compliant, including the ability for you to opt-out of marketing communications.

7. RETAINING PERSONAL INFORMATION

7.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 ​We will not keep your personal information for longer than is necessary for the business purpose or purposes set out in this policy or for legal reasons.
7.3 We will also retain your personal information:
7.3.1 ​to the extent that we are required to do so by law;
7.3.2 ​if relevant to any ongoing or prospective legal proceedings and
7.3.3 ​in order to establish, exercise or defend our legal rights purposes of fraud ​​​prevention and reducing credit risk.

8. SECURITY

8.1 We will take implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.
8.2 ​We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
8.3 ​You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.4 ​The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you to not share your password with anyone.

9. AMENDMENTS

9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

10. Your rights

10.1 ​You may instruct us to provide you with any personal information we hold about you; we will provide such information subject to:
10.1.1 ​the payment of a fee (currently fixed at SGD 10); and
10.1.2 the supply of appropriate evidence of your identity (for this purpose, we will usually ​accept a photocopy of your passport certified by a solicitor or bank plus an original copy of ​a utility bill showing your current address).
10.2 We may withhold personal information that you request to the extent permitted by law.
10.3 You may instruct us at any time not to process your personal information for marketing purposes. You may also instruct us to amend or delete your personal information by getting in touch with us as provided in this policy. If you do so, we may no longer be able to provide services to you.

11. THIRD PARTY WEBSITES

11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 ​We have no control over, and are not responsible for, the privacy policies and practices of third parties.

12. UPDATING YOUR INFORMATION

12.1 ​The Settings feature in the Dashboard, should allow you to edit or change any personal information.
12.2 ​In case, you need any additional details to be changed, which you have not been able to access using Settings feature, please let us know if the personal information that we hold about you needs to be corrected or updated.

13. CONTACT DETAILS

13.1 This website is owned and operated by Planar Investments Private Limited.
13.2 ​We are registered in Singapore under registration number 201323088H.
13.3 ​​Our principal place of business is at 1 Phillip Street, 03-02, Singapore – 048692.
13.4 ​​You can contact us by writing to the business address given above, by using our website contact form, or by email to support@trackwealth.com.
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