Policy Effective Date: February 15, 2023
Personal Information Collected
We collect the following personal information from you:
- Contact information such as name, email address, mailing address, phone number
- Billing information such as credit card number and billing address
- Financial information such as bank or brokerage account numbers, types of investments
- Social Security number
- Username, account number, password
- Demographic information such as age, gender, and zip code
- When you download and use our Services, we automatically collect information on the type of device you use, the operating system version, and the device identifier
While we collect information on the beneficiary of your accounts created, we want you to feel completely comfortable sharing this information, considering it may pertain to your young children. We want to reassure you that this shared information is only used for account creation, maintenance, and growth statistics. It will never be shared with third parties.
The security of your Personal Information is critical to UNest. When you enter information, such as a bank account number or financial information, on our forms, we encrypt it and only use it for set-up and maintenance, both automatic and requested, for your account. UNest uses bank-level security to keep your sensitive financial data safe. In addition, we use the strongest browser encryption (265 bit), and secure servers monitored 24/7.
UNest takes reasonable steps to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables data transmission is ever fully secure or error-free; therefore, we cannot guarantee the security of any information you transmit to us.
Information Regarding Children
Due to the nature of our business, Services, and benefits are not marketed to minors. Except for beneficiary information as described above, UNest does not knowingly solicit Personal Information from children under the age of 18.
If you are under the age of 18, please do not submit any Personal Information to UNest. If we learn that we have collected Personal Information directly from a minor, we will remove such information from our files.
If a parent or guardian becomes aware that their child under the age of 18 has provided us with Personal Information without their consent, they should contact us at firstname.lastname@example.org, and we will delete such information from our files.
Other Ways We Collect Information
Other means by which we collect Personal Information include the following:
- Anonymized or aggregated Information. UNest’s Site and App automatically record certain information about your use or evaluation of our Service. Anonymized or aggregated information is used for many things, including measuring Users’ interest in and using various site features. This information is not Personal Information, and we may use such information to analyze and research internally. In addition, we may share this information with third parties in an anonymized or aggregated form designed to prevent anyone from identifying you.
- Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
- Site and App Activity. UNest may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site and App.
- “Do Not Track” Technology. We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different websites or online services.
User Personal Information
We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your Personal Information in a number of ways, including research, internal analysis, and analytics.
Client Personal Information
UNest stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services, and provide our Services to clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a client.
Additionally, we may share the information required to become a client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you.
Information Sharing and Onward Transfer
We will not sell, rent, or trade your Personal Information (whether you are a current or former client) to any non-affiliated third parties without your permission except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, or situations involving potential threats to the physical safety of any person.
In certain circumstances, we may share your Personal Information with non-affiliated third parties without further disclosure to you. For example, we hire third parties from time to time to perform particular business and technology-related functions (e.g., mailing information, database maintenance, and payment processing). If we hire a third party to perform a function of this kind, we aim to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your Personal Information.
Your Choices and Opting Out
You may decline to provide Personal Information to UNest. However, declining to provide Personal Information may disqualify you from UNest services and Site features that require certain Personal Information.
Opting-Out – Obtaining and Withdrawing Consent
Where you have consented to UNest’s use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us via the email address indicated in the Contact Information Section below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and allow you to opt-out.
Before disclosing sensitive Personal Information to a third party or processing sensitive Personal Information for a purpose other than its original purpose or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will have to comply with the aforementioned law or contract.
We will only use Employee Personal Information for employment-related purposes. If we intend to use this Employee’s Personal Information for any other purpose, we will provide the Employee with an opportunity to opt out of these uses.
Retention and Deletion
You may request the deletion of Personal Information by contacting us at email@example.com and providing us with enough information to identify your account and prove that you are the owner of the specified account. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. We will not share any personal trading data unless regulators or other government bodies require it.
California Privacy Rights
California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third- parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. UNest does not share Personal Information with third parties for its own marketing purposes.