Goal Based Investors, Inc. (“GBI,” “we,” “our,” and/or “us”) values the privacy of individuals who use our mobile applications, including our Investor App and Advisor App, our website, and related services (collectively, the “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of the Services (“Users”) or their devices.
This Privacy Policy applies to Users of the Services while they are using and interacting with Advisors, Investors, or other Users through the Services. Please note that any information that you share off the Services, including as an Investor communicating with any Advisor with whom you previously connected through the Services will not be subject to this Privacy Policy. To understand how any Advisors process information from or about you that is obtained outside of the Services, please refer to such Advisor’s privacy policy.
By using or accessing the Services, you agree to the collection, use, disclosure, sharing, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of the Services is also subject to our Terms of Service.
Information We Collect
We collect a variety of information from or about you or your devices from various sources, as described below.
If you do not provide your information when requested, you may not be able to use the Services if that information is necessary to provide the Services or if we are legally required to collect it.
A. Information You Provide to Us
Registration and Profile Information. If you download the Investor App and create an account as an Investor, we ask you for your name, email address associated with your Apple ID, profile picture, information about your investment goals, which can include saving for retirement, for college, to buy a house, for a rainy day fund, or for other goals. We collect information like target dates to reach your goals, target annual income, anticipated down payment, anticipated cost of tuition, target rainy day fund, planned future savings, portfolio preferences, and other information.
If you download the Advisor App and create an account as an Advisor, we ask you for your name, city, state, company, profile picture, email address, CRD number, gender, years of experience, advisory style (such as advising, planning, market perspective, and plan course correction), communication style, and other information. We also give you the option to enter a link to your calendar for scheduling purposes.
Communications. If you contact us directly, we may receive additional information about you. For example, when you contact us via our “Contact Us” form on our website or for customer support, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.
Careers. If you decide to apply for a job with us, you may submit your contact information and your resume to us via email. We will collect the personal information you choose to provide us as part of your job application, such as your contact information, education, and employment experience.
B. Information We Collect When You Use the Services
Device Information. We receive information about the device you use to download or access the Services, including unique device identifiers, device model, operating system name and version, internet protocol (“IP”) address, web browser type, and mobile advertising identifiers.
Usage Information. To help us understand how you use the Services and to help us improve them, when you use the Services, we automatically receive information about your interactions with the Services, including log files, performance logs, diagnostic reports, the pages and content you view, the websites, invitations, or other sources that brought you to the Services, your in-app activity, including the other Users and individuals you interact with and number of goals or proposals you have created, and the times, dates, and durations of your use of the Services.
Location Information. When you use the Services, if you allow us, we receive your precise location information. We may also collect the precise location of your device when the Services are running in the foreground or background. We use your location information to personalize the Services, including to make it more convenient to connect with Advisors or Investors near you, as well as for attribution and conversion measurement services. We also infer the general physical location of your device and the geographic regions our Users come from. For example, your IP address may indicate your general geographic region.
Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
C. Information We Receive from Third Parties
Partners. We may receive additional information about you from third parties such as data or marketing partners and combine it with other information we have about you.
Other Users. We may receive additional information about you from other Users, including through customer support inquiries and from Users with whom you connect on the Services.
Asset Managers. If you are an Advisor, we may receive information about you, such as your name, company, email address, and CRD number, from asset managers who would like to make investment passes available to you in the Advisor App.
Third-Party Services. You may also post photos, comments, or reviews on our pages available through third-party platforms, including LinkedIn, Twitter and Facebook. If you do so, we and others may be able to view information that you make available through these third-party platforms.
How We Use the Information We Collect
We use the information we collect:
How We Share the Information We Collect
We may share or otherwise disclose information we collect from or about you as described below, permitted by law, or otherwise disclosed to you at the time of collection.
Partners and Affiliates. We may share any information we receive with our partners, subsidiaries, and affiliates, including our asset manager partners, for any of the purposes described in this Privacy Policy.
Vendors and Service Providers. We may share any information we receive with contractors, vendors, service providers, and other third parties retained in connection with the provision of the Services.
Advisors. If you are an Investor, the Investor App allows you to connect and communicate with Advisors about your investment, saving, and planning goals. Certain information that you make available in the Services, such as target goal dates and portfolio preferences will be viewable by Advisors by default to allow you to match with Advisors. Your last name and email address are not viewable by Advisors by default. We are not responsible for Advisors’ or any other Users’ use of available information, so you should carefully consider whether and what to post on the Services.
Investors. If you are an Advisor, the Advisor App allows you to connect with Investors and gives you a way to showcase how you can help Investors get their financial plans on track. Certain information that you make available in the Advisor App, such as your name, company, city, state, gender, and years of experience will be viewable by Investors by default. We are not responsible for the Investors’ or any other Users’ use of available information, so you should carefully consider whether and what to post on the Services.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you and for attribution and conversion measurement purposes. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) comply with requests from auditors, examiners, or other regulators; (c) respond to your requests; or (d) protect your, our, or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. We may disclose and transfer information about you to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.
At Your Direction. We may disclose information about you to fulfill the purpose for which you provide it.
Consent. We may also disclose information from or about you or your devices with your permission.
Your Choices
Profile Information. Certain information that you upload to your profile will always be publicly viewable to other Users through the Services to facilitate matches on the Services. If you are an Investor and connect with an Advisor, you can choose to share additional information about your goals and preferences, and if you are an Advisor who connects with an Investor, you can choose to share additional information about your financial planning experience and style. Please note that any information that you share off the Services, including as an Investor communicating directly with any Advisor with whom you connect will not be subject to this Privacy Policy.
Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings. However, location is core to the Services and without it, you may not be able to successfully use the Services.
Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
Third Parties
The Services may contain links to other websites, products, or services that we do not own or operate. The Services also allow Investors and Advisors to connect so Advisors can help Investors achieve their financial goals. We are not responsible for the privacy practices of these third parties, including Advisors that Investors connect with on the Services. Please be aware that this Privacy Policy does not apply to your communications with third parties or your activities on any third-party services or any information you disclose to third parties. We are not responsible for the privacy practices or the content of third parties or third-party sites. If you have any questions about how third parties or third-party sites use information from or about you, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.
Security
We make reasonable efforts to protect information from or about you by using technical and organizational safeguards designed to improve the security of the information we maintain. However, as the Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, please alert us at privacy@goalbasedinvestors.com.
Your California Privacy Rights
If you reside in California and have provided your personal information to us, you may opt-out from our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us by opting out in the privacy section of the Services.
International Visitors
The Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring information from or about you or your devices outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including information from or about you or your devices, on or to the Services, you consent to such transfer, storage, and processing.
Update Information
You can update information you provided to the Services by logging in to your account on the Services.
Changes to This Privacy Policy
This Privacy Policy may be revised from time to time. We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective as of the last updated date below. If we materially change the ways in which we use or share information from or about you or your devices previously collected from you through the Services, we will make reasonable efforts to notify you of the changes by sending a notice to the primary email address provided to us and/or by placing a notice on the Services.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@goalbasedinvestors.com.
Last Updated: 04-26-2022
