Privacy Policy

Invest Smart USA Privacy Statement

Last Updated on August 17, 2020

Invest Smart is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust. The following Privacy Statement applies to our sites, products, and services (collectively, “Services”) and outlines the types of personal information that Invest Smart USA, Inc. and Dynamic Life Planning Membership collectively as “Invest Smart”, “we”, or “us” collect, including through Invest Smart’s website (www.investsmartusa.com,) and our mobile applications for iOS and Android devices. It also explains why we collect your information and how we use it. We refer to those who establish an account with us (“Account”) or otherwise use our service
offerings as “users”. We refer to those who visit our website without logging into an Account or using our Services as “Visitors”. We refer to those who enroll in our Invest Smart Services as “Clients”. Together with our Terms of Use Agreement, this Privacy Statement governs your use
of our Services.
 

We NEVER rent, sell or trade your Personal Data (as defined below) to anyone. Ever.
 

If you have any questions, or if you believe that Invest Smart has not adhered to this Privacy Statement, please send us a note at info@investsmartusa.com.

 

Information We Collect and Why
 

“Personal Data” is your personally identifiable information such as your name, email or mailing address, phone number, account credentials, account numbers and any other identifier that we

gather from our Services or through communications with representatives of Invest Smart that can be used to identify you personally. Except as described in this Privacy Statement we don’t share your Personal Data with anyone. 

The types of Personal Data we collect depend on which of our Services you choose to use. The following are the types of Personal Data we collect at various stages of our relationship with you. We do not sell, share, or divulge Personal Data information pertaining to you to any unaffiliated third party except as outlined in the following seven categories:

1. Invest Smart offers many services, like the Employee Retirement Service, as well as third party services, where Invest Smart acts as an agent to retrieve your financial account information, such as your account balances, transactions, and holdings, from financial institutions you designate. Employee Retirement Service is a Service you may utilize by securely entering your financial account credentials, allowing us to securely connect with third-party financial institutions.
 

By accessing and using the Invest Smart Services, including but not limited to, Employee Retirement Service, you expressly authorize and direct Invest Smart, on your behalf, to electronically retrieve your account information maintained by third-party financial institutions with which you have a legally binding customer relationship.  Invest Smart may work with one or more third-party financial service technology providers to access and retrieve your account information.
 

Invest Smart is not responsible for and cannot guarantee the accuracy or timeliness of account information we retrieve on your behalf directly from third-party technology providers or from third-party financial institutions where your accounts are held, or from third-party market data providers used to provide the services.
 

You acknowledge and agree that the information you provide to Invest Smart through any third party financial technology provider will be treated by the third party financial technology provider in accordance with third party financial technology provider’s privacy policy, and by Invest Smart according to this Privacy Statement.

2. Account and Client Information
If you choose to create an Account or become a Client with Invest Smart, in addition to the information we collect from you as a visitor, as described below, we will also collect certain Personal Data, including your full legal name, email address, permanent address, birthdate, Social Security Number, citizenship, investment objectives, income information, and information about financial status. Under Federal and statutory law, we are required to collect this information to provide you with financial services. If you do not wish to provide this information, you may not be permitted to proceed to become an Invest Smart Client.
 

In the normal course of conducting business for you as an Account or Client, and acting as fiduciary on your behalf, we must necessarily share or disclose some data about you to custodial organizations (which typically also possess detailed information about you as their client), brokerage firms we may select to execute transactions on your behalf, clearing agent firms, and law firms pursuing shareholder class action suits. These organizations have their own privacy and client confidentiality obligations and procedures in place. It is important to understand that we would not be able to conduct business on your behalf without disclosing certain information about you and your account(s) to these affiliated and unaffiliated third parties.
 

3. Disclosure of Information with Your Consent
In the normal course of Invest Smart business, you may routinely ask us to provide Personal Data concerning profit and loss records, asset cost basis, portfolio market value, etc., to accountants, attorneys, and other financial professionals. Invest Smart is always pleased to comply with such requests, but we ask that you provide written or electronic consent in order to ensure the release of Personal Data.
 

4. Disclosure of Data to Legally Empowered Regulatory Entities and Law Enforcement
Invest Smart is subject to registration requirements with the State of Arizona. Regulatory authorities or Law Enforcement are empowered by law to perform certain audit functions to ensure Invest Smart complies with federal, state, and local laws governing Registered Investment Advisors. In the course of performing such audit functions, regulatory authorities may request information concerning you and/or your accounts. In complying with such requests, we take all possible steps to ensure your information is protected and not removed from our offices in any form where it might become subject to public disclosure under applicable state and federal laws.

5. Retirement Plan Sponsor and Participant Information

When a company creates an account with Invest Smart as a retirement plan sponsor, we will collect information on both the company and its employees as plan participants, including but not limited to, the company’s name, the company’s employer identification number, details about the company’s existing retirement plans, an email address of the company’s contact person and other relevant plan information. We will also collect certain personal and financial information about the plan participants, including, but not limited to, names, social security numbers, dates of birth, annual incomes, addresses, length of service with the company, gender, marital status, dates of hire, email addresses and other contact information, occupation, industry, personal interests, bank account balance, salary information and contribution rates.

6. Additionally, we may use your Personal Data to contact you regarding our own Services or resources that we think may be of interest to you. If you no longer wish to receive such marketing communications from Invest Smart, please click the “unsubscribe” link that can be found at the bottom of each such email message. Please note that if you hold an Account or are a Client with Invest Smart, you cannot opt-out of certain communications related to the administration of your Account, including communications related to billing, statement, trade confirmation delivery or certain regulatory matters.
 

7. There are certain circumstances, outlined below, in which we may share your Personal Data without further disclosure to you. From time-to-time, we hire other companies to perform certain
business and technology related functions (e.g. mailing information, database maintenance, consumer identification verification and payment processing). In order to provide financial services and in connection with our everyday business purposes and activities, we may share your Personal Data with third parties who perform services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, (e.g., if you ask to transfer assets from Invest Smart to such financial institutions).

We may collect and use "non-Personal Data" that we obtain from your website and mobile app activities, such as browser information and information obtained from our use of cookies and pixel tags. This includes information that you do not explicitly provide to us, but which may be implicitly provided to us as part of such activities. Similar to other technology platforms and services, Invest Smart records information such as browsing activity, data displayed or clicked on (such as UI elements and links), and other information (such as browser type, IP address, date and time of access, cookie ID, and referrer URL). Along with cookies, Invest Smart may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the Site. 

Visitor Information
We may collect various types of anonymous information about visitors to Invest Smart Services, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Invest Smart site, browsing activity, and any site that referred you to Invest Smart). We also collect information that you input into our website, (e.g., by beginning the Account application process or by commenting on the Invest Smart blog). Further, we may also collect Personal Data if you contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). We use this information to better understand our visitors and our
business, facilitate site navigation, provide customer support, operate and maintain your Account in accordance with US law, provide the services or information you request, and enhance the Invest Smart Services.

Advertising Companies

Invest Smart may advertise our Services on websites not affiliated with Invest Smart, and we may contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. We do not provide any information to these advertising companies that could personally identify our users or clients, and they do not collect such information for or from us.
 

Analytics Services
We may use third-party analytics tools, including “Google Analytics” and “Facebook Ads” (such tools collectively referred to as “Analytics Services”) to collect information about the usage of our site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve our site. These Analytics Services collect the IP address assigned to you on the date you visit our site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to our site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
You can prevent Google Analytics from recognizing you on return visits to any site by disabling cookies on your browser. You can opt-out of Google Analytics by installing the
Google Analytics Opt-out Browser Add-on here.

We use these technologies to customize Invest Smart and improve your experience with the site. Except as required by law or requested by regulatory authorities, Invest Smart agrees to maintain your non-public Personal Data in strict confidence.

Safeguarding and Disposal of Client Information

Invest Smart works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We store all of our data on servers in secure facilities and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Invest Smart to agree to keep your information confidential. 

Invest Smart takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, alteration, disclosure, or destruction.  If you maintain a Invest Smart account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer and mobile device.
 

If you choose to close your Account or your Account is terminated with us, we will continue to adhere to the Privacy Statement and practices outlined here. 

Safeguarding and Disposal of Client Information
 

Invest Smart USA, Inc. restricts access to NPI to those employees who need to know such information to provide services to our Clients.
 

Any employee who is authorized to have access to Personal Data is required to keep such information in a secure compartments or receptacle. All electronic or computer files containing such information shall be password secured and firewall protected from access by unauthorized persons. Any conversations involving Personal Information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.
 

Safeguarding standards encompass all aspects of the Invest Smart USA, Inc. that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that Invest Smart may adopt include:
 

•    access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent employees from providing customer information to unauthorized individuals who may seek to obtain this information through fraudulent means (e.g., requiring employee use of user ID numbers and passwords, etc.);
•    response programs that specify actions to be taken when the firm suspects or detects that unauthorized individuals have gained access to customer information systems, including appropriate reports to regulatory and law enforcement agencies;
•    measures to protect against destruction, loss, or damage of customer information due to potential environmental hazards, such as fire and water damage or technological failures (e.g., backup and store off site key data to ensure proper recovery); and
•    information systems security should incorporate system audits and monitoring, security of physical facilities and personnel, the use of commercial or in-house services (such as networking services), and contingency planning.

Any employee who is authorized to possess "consumer report information" for a business purpose is required to take reasonable measures to protect against unauthorized access to or use of the information in connection with its disposal. 

 How You Can Access or Change Your Personal Data That We Have Collected
 

Once you have registered with Invest Smart, you may request your Account be deleted by our support department by emailing info@investsmartusa.com from the email address associated with your Account, indicating “CANCEL” in the subject line of the message. After confirming you are the Account owner, we will remove Personal Data from our ongoing records and will only continue to retain such information as required by law. Unless you request otherwise, we will retain the Personal Data we collect from you indefinitely. Due to US legal and regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of five years.
 

Updating Your Personal Data
In connection with your right to manage your Personal Data you provide to us, you may access, update, change, correct your information either through the Service or through our customer
support. You can reach our customer support by using the email address info@InvestSmartusa.com or the Contact page on our website (www.investsmartusa.com)
 

Email Marketing Opt-out
When we communicate our own marketing offers to you, these communications are CAN-SPAM compliant, including the ability for you to opt-out of marketing communications.
 

Other Important Information
 

Do Not Track
Like most other companies, our Services are not currently configured to respond to browsers' "Do Not Track" signals, because at this time no formal "Do Not Track" standard has been adopted. Click here for more information on "Do Not Track."

Former Clients
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current Clients.
 

How You Accept This Privacy Statement

By using and continuing to use the Invest Smart websites, mobile apps and/or Services, or otherwise providing us with Personal Data (such as an email address) you agree to the terms and conditions of this Privacy Statement and any updates thereto. This Statement may change from time to time. This is our entire and exclusive Privacy Statement and it supersedes any earlier version. Our Terms of Use take precedence over any conflicting privacy statement provision.

Clients of Invest Smart will receive an initial notice of the Privacy Statement upon signing an Invest Smart Agreement, and, as long as the Client relationship continues to exist, Invest Smart is required to provide an annual privacy disclosure to its customers describing the Invest Smart Privacy Statement.

Changes to the Privacy Statement
From time-to-time, we may modify this Privacy Statement without prior notice by posting a new version of this Privacy Statement (www.investsmartusa.com). Any changes to the Privacy Statement will be reflected on this page and will become effective immediately upon posting. Please check the effective date above to determine if there have been any changes since you have last reviewed the Invest Smart Privacy Statement.
 

Minors
Invest Smart Services are intended for and directed towards adults. Our Services are not directed to minors and we do not knowingly collect Personal Data from minors. If a parent or
guardian becomes aware that his or her child under the age of 18 has created an Account with Invest Smart and/or provided us with personally identifiable information, please contact us at
info@investsmartusa.com.
 

Social Media
This Privacy Statement and these terms apply only to Invest Smart Services. This Site may contain links that access other websites and apps that are not operated or controlled by Invest
Smart. The policies described herein do not apply to Third Party websites or applications.
 

Your Rights as a California Resident
 

We do not share the Personal Data of CA residents with third parties for marketing purposes without consent.

International Visitors
This Service is hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy statement.

Questions

 If you have any questions or comments on the Privacy Statement, please contact us at:
 

Invest Smart USA, Inc.
7440 E. Pinnacle Peak Rd, .Suite 144
Scottsdale, AZ 85255
info@investsmartusa.com
1-480-389-0111