Your Privacy Matters

Contourdeli’s number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.

We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”) and to assist you in exercising your privacy rights.

Introduction
Contourdeli Corporation and/or its affiliates (“Contourdeli”, “we”, “us” and/or “our”) currently offer a cash product, financial planning software and portfolio management services, and may offer additional products and services in the future (collectively, the “Services”), through Contourdeli’s website, www.contourdeli.org (“Site”) and our mobile applications (“App”). This Privacy Policy describes how Contourdeli treats your Personal Information when you use our Site, App and/or Services.

For the purpose of this Privacy Policy, a “User” is a party who creates an account on our Site or App only to use our free financial planning software and/or to understand or evaluate our Services; and a “Client” is a party (including a User) who signs one of our Client Agreement for any reason, including to open a Cash Account or engage in portfolio management services.

Our Privacy Policy, Website Terms of Use, Financial Planning Terms of Use, and Client Agreements, govern different aspects of your use of our Site, App, and Services.

Information Collection

The categories of information we collect from Users differs from what we collect from those who qualify as Clients. Examples of instances when we collect Personal Information include:

when you answer questions on the Site or in the App to determine what kind of portfolio we might recommend if you were to become a Client,
when you register to open an account either as a User or a Client,
when you contact our client service organization with questions, or
when you agree to enter one of our Client Agreements.
Wherever Contourdeli collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms, such as our Website Terms of Use and/or Financial Planning Terms of Use.

Information We Collect from Users and Clients

We collect Personal Information from Users and Clients, including but not limited to:

name, e-mail address, telephone number, zip code, Internet Protocol address, birth date;
investable assets, income information, and other financial planning information about your household; and
account numbers, routing numbers, and login credentials for the financial accounts you choose to link to our Services, any challenge and/or security questions associated with those linked accounts, and any information contained in those linked accounts. (Note: The section labeled “Information We Collect When Acting As Your Authorized Agent” provides additional details regarding how we use and protect this information.)
Additional Information We Collect from Clients Only
In addition to the information described above, Clients provide us additional Personal Information, including but not limited to:

your full legal name, contact information, birth date, Social Security Number, citizenship, and marital status;
the full legal name, birth date, and Social Security Number of any beneficiaries that Clients choose to list;
for purposes of identity verification, government-issued identification documents and self-portrait photographs (“selfie”); and
investment objectives, approximate net worth, tax information, and other information required by federal and industry laws and regulations, such as employment information and stock restrictions (see our Client Agreements).
You are not required to provide these items to us to become a User, but Users who choose not to provide these items to us will not be able to become Clients.

Information We Collect When Acting As Your Authorized Agent

Many of Contourdeli’s Users and Clients choose to input information from accounts at outside third-party financial institutions onto their Contourdelig dashboard on our Site or in our App. Although there is no requirement to do so, if you choose to enable Contourdeli to collect information from your outside accounts, Contourdeli retrieves your outside account information maintained by your outside financial institutions (“Outside Account Information”) as described in this section.

By linking your outside accounts to your Contourdeli account, you provide Contourdeli access to your Outside Account Information, which may include prior and current account balances, your transaction history, and holdings from your linked outside financial institutions. Portions of this Outside Account Information will be displayed on your Contourdeli dashboard. Contourdeli may use the Outside Account Information we receive to formulate your financial projections in Path, to move money between your linked outside financial institutions and Contourdeli in accordance with your instructions and authorizations (such as via our Automated Savings Plan), in connection with our fraud prevention activities, or for other purposes consistent with this Privacy Policy and the Services we provide to you. Contourdeli may also use aggregated Outside Account Information from our Users and Clients for purposes of deciding which products and services to offer in the future.

By choosing to use our Services to aggregate and analyze your Outside Account Information, you expressly authorize and direct Contourdeli, on your behalf, to access all Outside Account Information available via the login credentials you provide. You also authorize and direct Contourdeli periodically to refresh your retrieved Outside Account Information by re-accessing your linked third-party accounts using your login credentials for so long as the ACH link remains active. Contourdeli uses Yodlee, Inc. (“Yodlee”) as our third-party service provider for the collection, use, storage, and handling of data in connection with our account aggregation services and for purposes of verifying the outside accounts. Contourdeli does not store the login credentials for your linked third-party accounts after the credentials have been transmitted to Yodlee, but we may store your login names in encrypted form for purposes of fraud detection and prevention. As Contourdeli’s service provider, Yodlee is responsible for storing your credentials, collecting and processing your Outside Account Information, and providing it to us using the login credentials you supply. You can view Yodlee’s privacy notice here and Yodlee’s commitment to clients and consumers here. Any Outside Account Information that Contourdeli receives from Yodlee is in read-only format, and Contourdeli cannot alter the Outside Account Information maintained by your third-party institution. All transmissions of your Outside Account Information and your login credentials between Yodlee and Contourdeli are encrypted in transit. Contourdeli retains your Outside Account Information collected via this account-linking service in accordance with our regulatory recordkeeping requirements, as permitted by law, as described elsewhere in this Privacy Policy, and as required in connection with the maintenance of your account and the Services we provide to you.

Users may request deletion of their Outside Account Information in accordance with the “Retention and Deletion” section below. Contourdeli does not share your Outside Account Information with outside parties except in limited cases relating to fraud investigations. In such fraud investigations, we may share certain of your Outside Account Information with your linked third-party institution. We also reserve the right to share Outside Account Information with third parties as required by law. If you choose to remove or deactivate a link to an account with a third-party institution, we will not retrieve any new Outside Account Information for that account unless you re-link that account in the future.

Information We Collect via the Referral Program

Contourdeli manages referral programs that allow Clients to receive a benefit in exchange for referring an individual who becomes a Client. Participation in any of our referral programs is free and voluntary for our Clients. By participating, a Client is asked to provide to Contourdeli the name and e-mail address of each person to whom Client refers Contourdeli’s Services. We treat this information like all other Personal Information described in this Privacy Policy.

Information Regarding Children

Due to the nature of our business, our Services are not available to minors. Except for beneficiary information as described above, Contourdeli does not knowingly solicit Personal Information directly from or about persons under the age of 18.

If you are under the age of 18, please do not submit any Personal Information to Contourdeli.

If you are a parent or guardian who becomes aware that, without your consent, your child under the age of 18 has directly provided us with Personal Information, you should contact us at support@contourdeli.org, and we will delete such information from our files to the extent permitted by regulatory requirements.

Other Ways We Collect Information

Other means by which we collect Personal Information include the following:

Automatic Data Collection: When you use our Services, we may collect your Internet protocol (“IP”) address; cookie identifiers; mobile carrier, mobile advertising and other unique identifiers; details about your browser, operating system or device; location information; Internet service provider information; pages that you visit before, during and after using the Services; information about the links you click; and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

Anonymized or Aggregated Information: Contourdeli’s Site and App record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of purposes, including the measurement of Users’ and Clients’ interest in and use of various portions or features of the Site and App. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including for internal analysis and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Cookies and Pixels: Similar to other consumer internet services, Contourdeli uses cookies, a small piece of computer code that enables our Web servers to identify Users and Clients, each time an individual initiates a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your hard drive at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.

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 Site. 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. Contourdeli may also use third-party tracking technology, such as Google Analytics, to record 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.

Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.

How we use Information

No Renting, Selling or Trading Out List
We will never rent, sell or trade your Personal Information to anyone. Ever.

User Personal Information
We utilize the Personal Information of our Users for a variety of business purposes, such as to help our Users evaluate our Services, offer new products and services, enhance our Services, and for research and internal analysis.

Client Personal Information
Contourdeli stores, processes, and maintains Personal Information of our Clients for a variety of business reasons such as to provide client support, analyze and improve our Services, offer new products and services, and provide our Services to Clients in accordance with the rules of regulatory authorities..

Identity Verification for Clients
We may use third-party vendors for identity verification. These vendors analyze whether the Client’s “selfie” matches the government-issued identity document. The information collected from Client photographs may constitute biometric information in some jurisdictions. Where required by law, we will seek consent from you prior to any such collection. We require our third-party vendors who support identity verification to agree to destroy any potential biometric data that is created or gathered for purposes of verifying your identity no more than ninety (90) days after its collection.

Cross-Device Tracking
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your computer. To do this, we may analyze your browsing patterns, geo-location and device identifiers to match the information of the browser and devices that appear to be used by the same person.

Social Media and Links to Other Websites and Applications
This Privacy Policy and these terms apply only to Contourdeli-operated Services and applications. Please note that our Site and Apps may for your convenience contain links to other websites, applications, social media accounts, and information that are not operated by Contourdeli. Contourdeli does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Information you choose to provide to linked third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of each company or website before submitting any Personal Information. Some third parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Mobile Computing
Contourdeli provides websites and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our Site are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download tools, such as an application, widget or other tool, that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Contourdeli to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Privacy Policy or in other notices we provide.

Promotional Activity
We may run sweepstakes and contests. The contact information you provide may be used to reach you about the sweepstakes or contest and for other Contourdeli promotional or marketing purposes. In some jurisdictions, we are required to publicly share some winner information.

Information Sharing and Onward Transfer
We will not share or disclose your Personal Information (whether you are a current or former User or Client) to any unaffiliated third parties except:

To Protect Ourselves or Others: We may share your Personal Information 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, situations involving potential threats to the personal safety of any person if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our or others’ rights, property, or safety; enforce our policies or contracts; or collect amounts owed to us.

Affiliates: Contourdeli may share your Personal Information among affiliated Contourdeli entities in connection with the provision of Services to Clients and Users.

Service Providers: There are certain circumstances in which we may share your Personal Information with unaffiliated third-party service providers, including to perform certain business and technology-related functions and to support the provision of the Services. We may share your Personal Information with unaffiliated third-party service providers for the provision of certain services, including but not limited to the following: mailing information; trade settlement and clearing; data processing and storage; payment processing; identification verification and fraud detection; customer support; and marketing. We do not share Personal Information with any third parties for their own marketing purposes.

Business Partners: We may provide Personal Information to business partners with whom we jointly offer products or services. For example, we may share the information required to become a Client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide and facilitate the provision of Services to our Clients.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract.

Your Choices and Opting Out

General
You have choices regarding the use and disclosure of your Personal Information, as set out in this Privacy Policy.

You may decline to provide Personal Information to Contourdeli. Declining to provide Personal Information may disqualify you from using Contourdeli Services, the Site, the App, and other features that require certain Personal Information.

Opting-Out – Obtaining and Withdrawing Consent
Where you have consented to Contourdeli’s use of your Personal Information, you may withdraw that consent at any time by contacting us by email or physical mail via the contacts indicated under the “Questions and Contacting Us” section below. Clients and Users cannot opt out of providing Contourdeli Personal Information and continue to use the Services. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal and regulatory purposes as described above. In addition to withdrawing consent by contacting us, Clients and Users must close their account(s) in order to opt out of further providing Contourdeli with Personal Information.

Before we use Personal Information for any new purpose we will provide information regarding the new purpose.

Email and Telephone Communications
Contourdeli may use your Personal Information to communicate with you regarding our Services or to tell you about blog posts or Services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at support@contourdeli.org. Please note that you cannot opt out of administrative communications such as regulatory, billing, or service notifications, or updates to our Terms or this Privacy Policy.

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

Mobile Devices
We may send you push notifications through our mobile application. You may at any time opt out of receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

Accessing Your Personal Information
Users or Clients may contact us at support@contourdeli.org to request information about how to access your Personal Information.

Contourdeli provides all Clients with continuous access to their Personal Information via the Site which contains information about account status, securities positions, and balances.
Clients can access or amend their Personal Information at any time by signing in to their Contourdeli account via our Site or App.
Your requests will be processed consistent with existing laws, including without undue delay and in accordance with any required time frames. Although Contourdeli makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information is protected from disclosure by certain privileges and protections, where doing so would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within one month of the request, a contact point for any further inquiries, and any other legally-required information. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your Personal Information.

Retention and Deletion
Contourdeli retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site, App, or Services, or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

Due to regulatory recordkeeping obligations, we may retain information related to you and your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies, to support processing of settlement of your transactions, or in accordance with applicable laws.

User Deletion Requests. If you are a User (as defined in the Introduction of this Privacy Policy) you may request deletion of Personal Information by contacting support@contourdeli.org and providing sufficient information to identify your account and prove that you are the owner of the identified account or an authorized representative. Please note, if you utilize a third-party data deletion request company to make these requests, you must personally provide us with separate written authorization before we will process your request.

Client Deletion Requests. In connection with separate regulatory recordkeeping obligations imposed on Contourdeli, we generally must maintain and cannot delete Personal Information associated with our Clients.

Other Important Information

Security

Contourdeli takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free; therefore, we cannot ensure or warrant the security of any information you transmit to us.

International Transfers

In certain cases, Contourdeli may transfer Personal Information internationally. We handle any Personal Information transferred internationally in accordance with this Privacy Policy and take measures to protect that information.

State Privacy Laws

California law permits Users and Clients who are residents of California 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 those third-parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Please note that this disclosure requirement only applies if we share Personal Information with third parties for those third parties to directly market their own products to those consumers, and Contourdeli does not share Personal Information with third parties for those third parties to directly market their own products to Users or Clients.

Under the California Consumer Privacy Act Users who are California residents may request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request.

As noted above in the “Retention and Deletion” section, Users may also request the deletion of Personal Information Contourdeli has collected. Because of separate legal obligations imposed on Contourdeli, however, similar deletion requests by those who qualify as Clients generally cannot be accommodated.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. If there are material changes to this Privacy Policy, we will notify you as required by applicable law.

Contourdeli encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with Contourdeli after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided to you by us. Each version of this Privacy Policy will be identified on this page by its effective date.

This document constitutes Contourdeli’s complete Privacy Policy for Contourdeli and its affiliates and the Services, Site and App.

Questions and Contacting Us

If after reviewing this Privacy Policy, you would like to submit a request to exercise your rights as detailed in this Privacy Policy or have any questions or privacy concerns, please contact us by email at support@contourdeli.org or via physical mail at:

612 Anton Blvd STE 700, Costa Mesa, CA 92626, United States