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Introduction

Financially Empowered LLC (“Financially Empowered” (or “we” or “us” or “our”) cares about your privacy and the security of your information, and we want you to understand how we collect, use and disclose your information. This Privacy Policy discloses our privacy practices with respect to your access to and use of the FinanciallyEmpowered.com website, our email newsletters, social media pages, mobile and other applications owned and operated by us, and any other services associated therewith (“FE Content”), which are provided by Financially Empowered. This Privacy Policy governs Financially Empowered’s collection of information from you through your use of FE Content. It does not apply to any information you may provide to Financially Empowered through other means, e.g., via mail or via telephone. Please read this Privacy Policy carefully so that you understand Financially Empowered’s online privacy practices. By using FE Content, you agree that your visit to, download or use of FE Content, and any dispute over Financially Empowered’s online privacy practices, is governed by this Privacy Policy and Financially Empowered’s Terms and Conditions of Use. Questions regarding privacy issues should be directed to Legal@FinanciallyEmpowered.com or to Financially Empowered, Attn.: Legal Dept., 865 Via de la Paz #300, Pacific Palisades, Calif. 90272.

Information we collect

Financially Empowered may collect and store information, personal or otherwise, that you supply either voluntarily or while navigating FE Content. That information may include personal information (e.g., information that identifies you as an individual or relates to an identifiable individual), technical information (e.g., device identifier, Internet protocol (“IP”) address, browser type, or operating system), and usage information (e.g., how you use, navigate, and respond to FE Content and information about content or advertisements you have been shown or have clicked on). We may combine these types of information together, and collectively refer to all of this information in this Privacy Policy as “Information.”

Information You Voluntarily Give Us. In connection with your use of FE Content, Financially Empowered collects identity and contact Information you voluntarily supply when registering for optional subscriptions and setting/adjusting subscription preferences or otherwise interacting with FE Content. Examples of this type of Information include the personal information you provide when you subscribe for FE Content (e.g., your name, job title, organizational affiliation, and email address). Supplying such Information is entirely voluntary. However, if you choose NOT to supply the requested Information, Financially Empowered may be unable to provide you with services made available to other users of FE Content.

When you interact with FE Content you may share other Information about yourself by, for example, signing up for a webinar, downloading a report, requesting a demo, or applying for jobs. This type of Information may include your name, email address, phone number, state, and resume.

Information Collected Automatically. We also collect certain usage and technical information regarding your navigation through FE Content and interaction with emails. As is true of most websites, Financially Empowered may also collect and store information that is generated automatically as you navigate through FE Content, which may be stored in log files. This information includes cookies, tracking pixels, web beacons, users’ IP and email addresses, browser type, operating system, general location data and other information about your use of FE Content, including a history of the pages you view. See the “Cookies and Other Technologies” section below for more information on how we may use these technologies to collect this information.

Information Collected from Other Sources. We may also collect Information about you from other sources, including through interactive applications (such as mobile devices, third-party services, and embedded audio and video players), from co-branded partners, and from commercially available sources (such as data aggregators and public databases).

Financially Empowered may authorize the collection of Information by third party advertisers through advertising technologies deployed in ads that may appear on FE Content without separate consent. The collection and use of Information by these third-party advertisers is governed by the privacy policies of those third parties and is not covered by Financially Empowered’s privacy policy. We are not responsible for the privacy practices of those parties.

Sensitive personal information

We ask that you not send us, and that you do not disclose to us, any sensitive personal information (e.g., social security numbers, information related to political opinions, racial or ethnic origin, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, sexual preferences or sexual orientation) on or through FE Content or otherwise. Any requested information that relates to sensitive personal information can be left unanswered by you.

How we use the information

We use Information for the purposes described in this Privacy Policy or disclosed at the time of collection or with your consent.

To Personalize Your Experience. Financially Empowered uses the Information it collects from you in a variety of ways, such as customizing features and advertising that appear on FE Content. The Information you supply will help Financially Empowered provide the services requested, offer you enhanced or more personalized features, and tailor FE Content and advertisements to your perceived interests. Please note that all of the Information we collect about you may be combined to help us tailor our communications to you and to develop rich online content and services. We rely upon your consent to process the Information you voluntarily supply.

To Evaluate and Develop New Features, Technologies, and Improvements to FE Content. We use your IP address and the information obtained through cookies, web beacons, and similar technologies to deliver FE Content’s content to you upon request and to measure traffic within FE Content, as well as track access and use of FE Content across devices you use to access FE Content. Processing this Information is necessary for our legitimate interests to further develop, study and analyze how FE Content is used, to keep our website updated and relevant by tracking user interests, trends, and patterns, and to grow our business and inform our marketing strategy.

For Marketing, Promotion, and Advertising Purposes. Financially Empowered may use the Information you provide to send you advertisements on behalf of third parties through FE Content. We may also use third party advertising companies to target and serve some of the advertisements that appear on FE Content, and these companies likewise may use their own cookies, web beacons, and similar technologies to collect Information from users of FE Content. The Information collected by these companies may include the IP address of your computer.

These companies may use that Information, sometimes in conjunction with similar Information gathered from other websites, to deliver advertisements on FE Content, and possibly on other websites (e.g., if the third-party advertising company operates an advertising network), tailored to match the perceived interests of consumers.

To Communicate with You and Provide Updates. We may use your Information (a) to contact you for customer service purposes, (b) to inform you of important changes and additions to FE Content or the services offered over FE Content, (c) to provide you with updates on new data, products, events, invitations to participate in surveys, or messages from partners, and (d) to provide or deliver any other communications that Financially Empowered believes may be of interest to you. Our legal basis for processing this Information is based on your consent as well as for our legitimate interests to keep our records updated and to study how FE Content is used.

For Administrative, Compliance, and Legal Tasks. We may also use your identity and contact Information for (a) auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements, (b) fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks, and (c) sending you administrative notices, offers, and requests for feedback.

This Information may also be used in order to comply with various legal processes and to protect and enforce the rights and interests of Financially Empowered and others. Therefore, we may access, preserve and disclose Information if we are required to do so by law or we have a good faith belief that such action is necessary to (a) comply with the law or with legal process, (b) protect and defend our rights, safety and property, including in connection with the Terms and Conditions of Use, (c) protect against misuse or unauthorized use of FE Content, (d) protect and defend the rights, safety and property of our users or the public (among other things, this means that if you provide false or misleading information or attempt to pose as someone else, Information about you may be disclosed as part of any investigation into your actions), and (e) cooperate with public and government authorities (which may be outside your country of residence). Processing this Information is necessary for running our business, e.g., complying with legal obligations, provision of administrative and IT services, network security, prevention of fraud, and in the unlikely context of a business reorganization or group restructuring.

Sharing your information

Financially Empowered may share your Information with third parties, such as service providers, contractors, and advertisers. For example, Financially Empowered may provide Financially Empowered’s advertisers with Information about you and other visitors that will enable Financially Empowered’s advertisers to better target advertisements that are more relevant to you.

Please also note that as Financially Empowered’s business grows, Financially Empowered may buy or sell various assets. We have a legitimate interest in disclosing or transferring your Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business (including in connection with any bankruptcy or similar proceedings). In the event that Financially Empowered is involved in any of the foregoing transactions, including the transfer of FE Content to another company, your Information may be among the transferred assets.

Your controls and your choices

We provide you the ability to exercise certain controls and choices in relation to our collection, use, and sharing of your personal information. In accordance with applicable law, you may have the following rights:

•   Right of access – the right to be informed of, and request access to, the personal information we process about you;
•   Right to rectification – the right to request that we amend or update your personal information where it is inaccurate
or incomplete;
•   Right to erasure – the right to request that we delete your personal information;
•   Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal information;
•   Right to object – the right to object to us processing your personal information;
•   Right to data portability – the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service; and
•   Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
•   You can exercise these controls and choices by contacting us at Legal@FinanciallyEmpowered.com.

Unsubscribing. You may also manage and modify your subscriptions, and otherwise limit our communications with you by contacting us at Legal@FinanciallyEmpowered.com.

Ad Choices. For more information about interest-based advertising on your desktop or mobile browser, and to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising Website.

If you experience any issues with unsubscribing or managing and/or modifying your preferences as described above, please contact us at Legal@FinanciallyEmpowered.com. Be sure to (a) provide your email address along with the name of the newsletter or subscription from which you would like to unsubscribe and (b) include “Opt Out” or “Change Preferences” in the subject line. By contacting us, you grant Financially Empowered permission to use your email address for purposes of responding to your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion.

You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. We would, however, appreciate the chance to deal with your concerns before you lodge a formal complaint so please contact us in the first instance.

Storage and retention of your information

We retain Information for as long as needed or permitted in light of the purpose(s) for which it was obtained, consistent with applicable law. The criteria used to determine our retention periods include (a) the length of time we have an ongoing relationship with you and provide FE Content access to you (e.g., for as long as you continue to use FE Content), (b) whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them), or (c) whether retention is advisable in light of our legal position (e.g., applicable statutes of limitations, litigation or regulatory investigations).

Information Security. We have put in place reasonable controls designed to help safeguard the Information we collect via FE Content. However, no security measures are perfect, and we cannot assure you that Information that we collect will never be accessed or used in an unauthorized way.

To further protect your data, we recommend that you use complex passwords for any accounts you have with us where password protection is offered as an option. Please do not use the passwords you use for FE Content for other services or share passwords with unauthorized persons. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us at Legal@FinanciallyEmpowered.com.

Third party sites

FE Content includes links to third party websites whose privacy policies Financially Empowered does not control. Once you leave FE Content, any Information you provide at another site will be governed by the privacy policy of the operator of the site you are visiting. The privacy policies of third-party websites will differ from ours.

Please note that if you make a purchase through a third-party site, the privacy policy of the third-party site will govern the use and distribution of your credit card number or other financial information.

Cookies and other technologies

To help make FE Content more responsive to the needs of users, Financially Empowered employs a standard feature of commonly used browser software, called a “cookie,” to assign each user a unique, random number that resides on a user’s computer. The cookie does not personally identify the user; it merely identifies the computer with which the user accesses FE Content. Unless a user voluntarily identifies himself or herself (through subscription, for example), FE Content will not be able to identify the identity of the user, even if a cookie is assigned to a user’s computer. The personal information a cookie can contain is information supplied by a user. Cookies prevent you from having to re-enter your preferences on certain areas of FE Content where you have previously entered preference information. Of course, you are free to set your web browser to not accept cookies; however, doing so may render your computer unable to take advantage of the personalized features enjoyed by other users of FE Content.

FE Content’s servers automatically collect limited information about your computer’s connection to the Internet, including your IP address. The IP address is a number that lets computers attached to the Internet know where to send data – such as the web pages users view.

Financially Empowered may also use web beacons (also known as “single-pixel GIFs”) to access cookies and to count users who visit FE Content or open Financially Empowered’s HTML-formatted email messages, as well as track device identification statistics and other non-identifying information for the purpose of analytics, push notifications, and error reporting. These analytics may be provided to third party vendors.

Do Not Track Notice. Financially Empowered takes privacy and security very seriously. We strive to put our users first in all aspects of our business. With regard to Do Not Track (“DNT”) signals, Financially Empowered currently does not respond to DNT signals in browsers because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Childrens privacy

This children’s privacy statement explains Financially Empowered’s practices with respect to the online collection and use of personal information from children under the age of thirteen and provides important information on children’s and parental rights under federal law with respect to such information.

FE Content is not directed to children under the age of thirteen and Financially Empowered does NOT knowingly collect personal information from children under the age of thirteen. In fact, Financially Empowered requires subscribers’ occupational information in part to dissuade users under the age of thirteen from subscribing. If Financially Empowered becomes aware that it has inadvertently received personal information from a user under the age of thirteen, Financially Empowered will delete such information from Financially Empowered’s records. Because Financially Empowered does not knowingly collect any personal information from children under the age of thirteen, Financially Empowered also does NOT knowingly distribute any such information to third parties. Financially Empowered does NOT knowingly allow children under the age of thirteen to distribute personal contact information.

International transfer

Our computer systems are currently based in the United States. This means Information we collect will be processed by us in the United States where data protection and privacy regulations may be subject to different requirements. If you use or visit our website from outside the United States, you consent to the collection and/or processing of the Information we collect from you in the United States.

Changes to this policy

We evaluate this Privacy Policy periodically in light of changing business practices, technology and legal requirements. As a result, we may update this Privacy Policy from time to time. In the event that Financially Empowered does update this Privacy Policy, the modified Privacy Policy will be accessible on FE Content and will be effective as of the date set forth below. We will notify you about material changes to this Privacy Policy by placing a notice on our website. Your continued use of FE Content after Financially Empowered modifies this Privacy Policy shall constitute your agreement to be bound by the terms hereof as modified.

California Privacy Notice

This section supplements our Privacy Policy and explains additional rights available to California residents as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). These rights apply solely to users that are California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”).

Your Rights. The CCPA provides California residents with specific rights regarding their California Information. Under the CCPA, you have the right:

To know what categories and specific pieces of California Information we have collected, used, or shared about you;
To know the categories of sources from which we collected your California Information;
To know the business or commercial purposes for which we collected or sold your California Information;
To know the categories of third parties with which we shared your California Information;
To delete your California Information that we have collected from you; and
To not be discriminated against for exercising any of these rights.

How to Exercise Your Rights. You can exercise your “right to know” or your “right to request deletion” by contacting us at Legal@FinanciallyEmpowered.com.

Please note that to protect your information we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity. When submitting a request, please be sure to indicate the right being exercised, and include your first and last name as well as the email address used when interacting with FE Content. A member of our team will review your request.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

California Information We Collect. In particular, we will collect the following categories of California Information from consumers:

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  • Contact information and other identifiers – such as name, job title, organizational affiliation, email address, phone number, and state of residence.

  • Unique and online identifiers – such as IP address, browser type, operating system, and other information about your use of FE Content.

  • Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with FE Content and content such as advertisements.

 

We obtain the categories of California Information listed above from the following categories of sources:

 

  • Directly from you while navigating FE Content or when you voluntarily register for optional subscriptions, downloading a report, requesting a demo, or otherwise interacting with FE Content.

  • Linked sites such as social media sites and third-party platforms

  • Information suppliers

  • Publicly available sources

  • Cobranded partners


Use of California Information. We may use or disclose the California Information we collect for one or more of the following purposes:

​

  • To communicate with you

  • To help deter fraud and prevent crime

  • To better provide the services requested

  • To offer you enhanced or more personalized features

  • To provide you with the opportunity to participate in surveys

  • To provide certain services to our customers (without disclosing your California Information)

  • To develop, maintain, provision or upgrade FE Content

  • To tailor FE Content, marketing, and advertisements to your perceived interests

  • To assist in internal research, analytics and development – e.g., user-preference analytics


Sharing California Information. Categories of parties with whom your California Information may be shared include:

​

  • Apps, websites, and third-party integrations on or using FE Content

  • Analytics Partners – These entities help us collect data on how FE Content is used, so that we can improve and better understand our consumers

  • Advertising Partners – These entities help us advertise our products or services, as well as connect us with others who want to place advertisements on some of our products or services

  • Cobranded Partners – We partner with these entities to jointly promote our products and services, for example by co-hosting webinars


We do not sell data that directly identifies you.

Contact information

If you have any questions or comments about this California Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise your rights under CCPA, please contact us at Legal@FinanciallyEmpowered.com

Introduction
Information we collect
Sensitive personal information
How we use the information
Sharing your information
Your controls and your choices
Storage and retention of your information
Third party sites
Cookies and other technologies
Childrens privacy
International transfer
Changes to this policy
California Privacy Notice
Contact information
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