privacy-policy – Wealthlane

Privacy Policy

Wealthlane Data Privacy Policy

Effective: May 30, 2024

1. Introduction.

Wealthlane Financial, Inc., including its subsidiaries and affiliates (collectively referred to herein as “Wealthlane”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you” or “your”) who visit our websites and/or use the Wealthlane equity compensation plan management software platform (the “Platform”). This Privacy Policy applies to data collection and privacy practices of Wealthlane and shall apply to your use of the Platform, the website, wealthlane.com, and other Wealthlane-related sites, communications, capabilities and services (“Services”) accessible on or by domain owned by us (each, a “Site” and collectively the “Sites”).

This Data Privacy Policy (the “Policy”) explains what personal information we collect about you, how we use, disclose and share that information, and the rights you have in connection with that information.

By accessing the Sites and/or using the Platform you agree to this Policy. If you do not agree with the Policy please do not use the Sites or the Platform.

If you have any questions, please submit a request to [privacy@wealthlane.co].

2. Information We Collect.[1]

As described in this Policy, we may collect information from you or about you in order to provide, enhance, and market the Services. This section describes the categories of personal information we may collect. For purposes of this Policy, personal information generally includes information that may be used to identify you. We only collect personal information in accordance with applicable law.

Categories of Personal Information We May Collect

Examples of Personal Information We May Collect

Collected?

Identifiers

Name, alias, home and work addresses, home and work phone numbers, mobile phone number, social security number, driver’s license number, passport number, tax identification number, other government-issued identification numbers, alien registration number, place and date of birth, personal and work email address, username and password, social media name, signature, customer identification number, IP address, electronic device (“Device”) identifier, device type, browser type, platform type

Yes

Financial information

Financial account number, trading activity, transactions, equity compensation, account history, income, debt, assets, revenue, credit history, credit score, investment experience, risk tolerance, and information about your personal investment goals or objectives

Yes

Protected classifications under California or federal law (“Protected Class Information”)

Age, sex, gender, national origin, citizenship, race, ethnicity, marital status, and disability status

Yes

Commercial information

Records of personal property, products or services purchased, obtained, or considered and other purchasing and consuming histories or trends.

Yes

Internet or similar network activity

Browsing history, search history, clickstream data, session information, navigation paths, and other information about how you interact with our websites and mobile applications

Yes

Biometric information

Physiological, behavioral and biological characteristics, activity patterns used to extract a template or other identifier or identifying information, such as heart rate, height, weight , gait or other physical patterns, and sleep, health and exercise data.

Geolocation Data

Physical location or movements

Yes

Sensory data

Audio, electronic, visual, thermal, olfactory or similar information.

Yes

Professional or employment-related information

Current or past job history, professional memberships, employee reference checks and trade union membership

Yes

Education information

Academic record, degrees, and schooling

Inferences from other personal information

Preferences, behaviors, characteristics (including, for example, age gender, race, and marital status), number of persons in household, and similar information

Yes

Sensitive Personal Information

Social security, driver’s license, state identification card, or passport number

Yes

In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including, but not limited to, accounts and transactions. This data, which we may use for our business purposes consistent with applicable law, does not identify an individual and is not personal information.

3. Sources of Personal Data and Purpose of Collection.

We obtain the categories of personal data listed above from the following sources:

· Directly from Users.

· Directly from our corporate Services customers and their agents.

· Directly and indirectly from activity on our Sites and Platform.

Personal Data is collected to allow is to perform the Services, to enhance the Services, to market, advertise, and promote the services, for information security purposes, and to comply with legal and regulatory obligations.

4. How we Use Personal Data that We Collect.

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

· To inform you about services available from Wealthlane;

· To authorize access to our Sites and Services;

· To provide you with services and products;

· To process applications for employment;

· To market, advertise, and promote the Sites and Services;

· To respond to and support Users regarding their use of the Sites and Services;

· To send you confirmations, updates, security alerts and support administrative messages and otherwise facilitate your use and our administration and operation of the Services;

· To perform data analysis and testing;

· To comply with all applicable legal requirements; and

· Otherwise to fulfill the purpose for which the information was provided

We use the information we collect from out Sites to provide, maintain and improve the Sites and Services, to develop new services and to protect us and our Users.

We and our service providers may use IP addresses to understand where our Users are accessing the Services. Unless prohibited by applicable law or regulation, we may combine and supplement information collected by one source with information obtained through other resources.

We use information collected from cookies and other technologies to improve your User experience and the overall quality of our Services. We may use your personal information to see which webpages you visit at our Sites and other browsing data to better understand our Users and improve our Sites accordingly.

5. Personal Data We Disclose and to Whom We May Disclose It.

We may disclose your Personal Data to third parties for a business purpose. When we disclose Personal Data, we seek contractual commitments to keep Personal Data as confidential and use it only for the purpose for which it was delivered. We may disclose Personal Data to the following third parties:

· Our affiliates;

· Financial brokers where the corporate client or individual has a brokerage account or will open a brokerage account in furtherance of the Services[2];

· Service providers and other third parties we use to support our business, including those performing core services, such as billing, customer support, accounting, and auditing;

· Government, regulatory and self-regulatory entities,

· Corporate clients (such as your employer) and their agents; and

· Third parties that you or your agents authorize us to disclose your Personal Data in connection with the Services.

In addition to the above parties, we may share Personal Data under the following circumstances:

· Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Wealthlane if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

1. meet any applicable law, regulation, legal process or enforceable governmental request.

2. enforce applicable Terms and Conditions including any investigation of potential violations.

3. detect, prevent or otherwise address fraud, security or technical issues.

4. protect against harm to the rights, property or safety of Wealthlane our Users or the public as required or permitted by law.

· Business Transfers. If we establish a new related entity, are acquired by or merged with another organization or if substantially all of our assets are transferred to another organization, personal data about our Users is often a transferred business asset. In the event that Wealthlane itself or substantially all of its assets are acquired, personal data about our Users may be one of the transferred assets. This includes due diligence in connection with any of the foregoing.

6. Notice to California Residents.

This section describes your rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”) and how to exercise those rights.

Right to be Informed. You are entitled to be informed of how we use your Personal Data. This Policy provides this information to you.
Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data over the past twelve (12) months. Our disclosure to you will only cover the 12-month period that precedes your request. If applicable, our response will explain the reasons we cannot comply with a request.
Right to Data Portability. You have the right to a portable copy of your Personal Data that you have submitted to us. This means you have a right to request that we move, copy or transmit your Personal Data stored on our servers or in our information technology environment to another service provider’s servers or information technology environment.
Right to Delete Your Data. You have the right to request that we delete your Personal Data that we collected from you and retained, subject to certain exceptions. Once we confirm your request, we will delete your Personal Data from our records, unless an exception applies. Please direct such requests to privacy@wealthlane.co
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right that Wealthlane cannot discriminate against you for exercising your privacy rights.
Right to Opt Out of Sharing Your Data. You have the right to request that we not share your Personal Data with any third parties.
Right to Correct Your Data. You have the right to request changes to your Personal Data if it is incorrect or outdated in any way.

Right to Stop Automated Decision Making on Your Data: You have the right not allow your Personal Data to be subject to automated decision making related to location and movement, personal preferences, behavior patterns or performance in the workplace.

You may submit a California privacy rights request via email to [privacy@wealthlane.co].

Upon receiving your request, we will review the nature of the request. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information you requested. We may also ask that you provide clarifying information. We will respond to authorized requests within the timeframe required by law. The above rights are subject to our ability to reasonably verify your identity and authority to make these requests.

Your California privacy rights are subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.

7. European Users’[3] Rights Regarding Personal Data.

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with rights in connection with Personal Data you have shared with us when we are the data controller. If you are a resident in the European Economic Area, you may have the following rights:

· The right to be informed. You are entitled to be informed of the use if your Personal Data. This Policy provides such information to you.

· The right of access. You have the right to request a copy of the Personal Data we hold about you.

· The right of correction. You have the right to request corrections or changes to your Personal Data if it is inaccurate.

· The right to be forgotten. You have the right to request that we delete records of your Personal Data. We will delete your Personal Data so long as there is no legal obligation or prevailing right for us to keep it.

· The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.

· The right to data portability. You have the right to a portable copy of your Personal Data you have submitted to us.

· The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to automated decision making and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.

· The right to lodge a complaint with a supervisory authority.

You can make these requests via email at [privacy@wealthlane.co]. We will consider the requests in accordance with applicable law.

8. Use of Cookies and Similar Technologies[4].

We, our affiliates and/or other persons acting on our or their behalf use cookies and similar technology, such as web beacons (also known as clear GIFs or pixel tags), or similar technologies as they may develop over time. We use cookies and similar technologies to collect, use, and share information when you visit our online services or interact with us online, e.g., via email or other electronic means.

9. Information on Individuals Under 18 Years Old.

Our online services are not directed to or intended for individuals under 18 years of age. We do not knowingly collect information from individuals under the age of 18 years without parental consent. If we become aware that an individual under 18 years has provided us with personal information without parental consent, we will take steps to remove the data as permitted by law.

10. Data Security.

We maintain reasonable physical, administrative, and technical safeguards to protect your personal information. Our employees and third-party service providers have access to your personal information only on a “need to know” basis. We have internal policies governing the proper handling of consumer information by employees and requiring third parties that provide support or marketing services on our behalf to adhere to appropriate security standards with respect to such information. Any requests to delete data should be sent to privacy@wealthlane.co.

11. Updates to this Policy.

We may update this Policy from time to time. We encourage you to periodically review this Policy to learn about updates to our privacy practices. Email us at privacy@wealthlane.co for any inquiries related to this policy.