MoneyGuide, Inc. Privacy Policy

MoneyGuide, Inc. ("MG"), the developer of MoneyGuidePro^® and moneyguidepro.com, is committed to protecting your privacy and ensuring the security of your information on our website.

Our Privacy Policy has three key elements.

1. You were granted access to moneyguidepro.com by a financial advisor. This financial advisor and, if applicable, the firm with whom they are licensed, also has access to your personal information on moneyguidepro.com. Your advisor uses your personal information, in conjunction with our software, to provide customized financial planning reports for you. Your advisor's use of your data is governed by their firm's privacy policy. Please contact your financial advisor if you have questions about their firm's privacy policy.
2. Your financial advisor can authorize MG to allow the exchange of data between moneyguidepro.com and other programs or websites that your advisor uses in their business, and your personal information can be included in these data exchanges. Except for data exchanges that have been authorized by your advisor, MG does not disclose or share your personal information with any third party, unless required by law to do so (for example, to comply with a subpoena).
3. We use transport layer security (TLS) encryption, which is the industry standard for secure data transfer software, to ensure data you transmit through the Internet is protected against unauthorized access.

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What Personal Information Do We Collect and How Do We Use It?

When you register, we will ask you for your name, email address, and contact information, and you will be asked to select a password. You may also be asked to select a user name.

We use your name to personalize your reports generated by the system. We use your email address to confirm your subscription, user name and password, and to provide customer service. As a registered user, when you select the option to create or access your financial plans, we will recognize you by your user name and password (or e-mail address, as applicable). We may also use the contact information we collect to notify you about any new functions included in our software or new services offered by our website.

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What Financial Information Do We Collect and How Do We Use It?

To use our software, you or your financial advisor must input personal financial data for you and, if applicable, your co-client. The personal financial data required may include annual income, current values of and annual additions to investment assets, anticipated retirement expenses, and expected values of future assets such as lump sum distributions from pensions or inheritances. In many instances, these entries are optional. This personal financial information will be used by your financial advisor, in conjunction with our software, to develop financial, asset allocation, and income plan(s) or analyses for you.

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"Cookies"

"Cookies" are small files used by websites to store information on your computer. For moneyguidepro.com to work properly, your browser must be enabled to accept cookies. Our cookies contain information that identifies you during a session and allows the software to function. This information is not for sale or distribution.

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How Do We Protect Your Information?

When you access your financial data, we use a state-of-the-art secure server to keep all your personal information as secure as possible. The transport layer security (TLS) encrypts all information you input before it is sent to us, and all data we collect is protected against unauthorized access. This approach helps ensure that your personal and financial information remains safe and private.

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Your Consent

By using our website, you consent to the collection and use of the information described above by moneyguidepro.com. Should we make any changes to our privacy policy, we will post those changes on this page, and your continued use of our website is your consent to those changes.

You also acknowledge that MG may aggregate data from its users and subscribers for the purpose of better understanding its user base and/or to research potential changes in content and services. MG may use this collective information for product research or marketing demographics, but we do not disclose, sell, or distribute any information to a third party where such information could indicate directly or indirectly any individual's financial information.

MoneyGuide Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in MG's privacy policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

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Information We Collect

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, MG has collected the following categories of personal information from its consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

MG obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from your financial advisor.
• From third parties. For example, from third parties in order to verify your identity and prevent fraud.

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Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, we use your name to personalize your reports generated by the system.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MG's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MG about our website users is among the assets transferred. MG will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

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Sharing Personal Information

MG may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Your financial advisor.
• Integration partners.
• Companies participating with Envestnet in a proposed or actual sale, merger, transfer, or business exchange.
• Other organizations as directed by you or your authorized representative.

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Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Your financial advisor.
• Data aggregators.
• Integration partners.

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Sales of Personal Information

MG does not sell, and in the preceding twelve (12) months has not sold, personal information.

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Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that MG disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that MG delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-743-7092
• Visiting www.moneyguidepro.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically PDF. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

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Changes to Our Privacy Notice

MG reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

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Contact Information

If you have any questions or comments about this notice, the ways in which MG collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-743-7092

Website: www.moneyguidepro.com

Email: support@moneyguide.com

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Effective Date: January 1, 2020

Last Reviewed on: December 5, 2019