We at Zoe Financial, Inc. (“Zoe Financial”) and our affiliated broker-dealer, Zoe Securities LLC (“Zoe Securities” and, together with Zoe Financial, “Zoe,” “we,” “us,” or “our”) know that data privacy is very important to you. We have created this privacy policy (this “Privacy Policy”) to describe what kinds of personal information we may obtain through:

• Our website located at https://zoefinancial.com/ (the “Website”);

• Our proprietary all-in-one wealth platform (the “Zoe Wealth Platform”), which is made available to you through the Website;

• Any other website, mobile application, or digital property that links to this Privacy Policy; and

• When you otherwise interact with us in any way.

  
  

By accessing or using the Website, the Zoe Wealth Platform, or any other website, web application, or digital property that links to this Privacy Policy (collectively, the “Digital Properties”), you may access or use our financial advisor matching and related services (collectively, the “Services”). Our Services are only available to individuals aged 18 or older. If you are under the age of 18, you may not use our Services.

By accepting this Privacy Policy, accessing or using any Digital Properties, the Services, or otherwise manifesting your assent to this Privacy Policy, you agree to be bound by this Privacy Policy. If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such parties to the terms of this Privacy Policy. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy you may not access or use the Digital Properties or the Services.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Website Terms of Use, as applicable.

1. The Information We Collect and/or Receive

In the course of operating the Website and the Platform, providing the Services, and/or interacting with you, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Contact Information

When you contact us via the Website, email or by mail, when you call us, when you book a demo of the Zoe Wealth Platform, you will be asked to provide certain information, which may include, your name, e-mail address, and any information provided in messages to us (collectively, “Contact Information”). The Contact Information is used to provide the requested service or information and to contact you for purposes of direct marketing of our current and future services.

2. Financial Advisor Matching Information

If you would like to use our “Find An Advisor” Services, you will be asked to provide certain personal information including, your name, email address, phone number, whether you currently have a financial advisor, your annual household income, financial goals (which could include retirement, home purchase, family planning, investments, and taxes), whether you own any cash, real estate, investment accounts, or retirement accounts and your zip code (collectively, “Financial Advisor Matching Information”). We will use this information to match you with one or more third-party registered investment advisers (“RIAs”) that participate in our Zoe Advisor Network.

3. Account Information

In order to access and use our Platform, each Authorized User will have to create an account on the Platform. In connection with creating an account, we collect your name, email address, password and other registration information (collectively, “Account Information”). We use the Account Information to process the creation of your account, including to verify your identity, and to manage your account.

4. Payment Information

In order to purchase Services, you may be required to provide our third party payment processor(s) (each, a “Payment Processor”) with certain credit or debit card information, ACH transfer information or wiring instructions (collectively, the “Payment Information”). We do not obtain access to the Payment Information. Our Payment Processor(s) will collect on our behalf information about your payment for Services (“Transaction Information”). By using the Services, you acknowledge and agree that if and to the extent your Payment Information, Transaction Information, and/or any other information is collected by or transferred to our Payment Processor, such information will be governed by its applicable privacy policy, and that you expressly agree to the terms of such privacy policy. You hereby expressly grant us the right, power, and authority to access and transmit your information as reasonably necessary for the Payment Processor to provide its services to you in connection with your use of our Services.

5. Services

Financial Advisor Matching Services: To access our “Find An Advisor” Services, you may have to provide Financial Advisor Matching Information. If you decide to engage the RIA we match you to through the Services, your RIA may create an investment/brokerage account on the Platform on your behalf. 

1. Investment/Brokerage Services: In order to use our Investment/Brokerage Services, you may have to open an account (each an “Investment Account”), depending on the Services you select. In order to open the Investment Account, you will be required to provide certain information in addition to Contact Information such as your date and country of birth, nationality, passport numbers (or numbers associated with other government issued identification), Social Security Number or Tax ID, gender, marital status, photo, employer name and address, financial information such as bank account and payment card details, suitability information, income, net worth revenue, and other sources of funds, account balance, credit scores, tax information and other information about financial situation, investment objectives and risk preferences and tolerance. Please review our Regulation SP Privacy Notice for a description of our processing and disclosure activities regarding the non-public personal information that we collect from and about you in connection with opening and servicing an Investment Account.
   
   

6. Information obtained automatically from your online activity

When you access or use the Digital Properties and/or Services we use browser cookies, pixels, web beacons, and similar technologies (collectively, “Tracking Technologies”) to automatically collect or receive certain standard technical information and other data (such as traffic data, usage data (including but not limited to, profiles viewed, matches made, features used, frequency and duration of the Digital Properties and/or Services usage, and interactions with content on the Digital Properties and/or Services, location data, device information (including but not limited to, type of device, mobile device platform, operating system, browser type, screen resolution, IP address and other technical information), logs and other communications data) sent to us by your computer, mobile device, tablet, or any other device over time on our Digital Properties and/or Services, and your online activity across third party websites, apps, and devices. We may also evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of our Digital Properties and Services.

When you access or use the Digital Properties and/or Services, analytics networks, and providers, and other third parties may use Tracking Technologies to collect information about your online activities over time and across different websites, apps, online services, digital properties, and devices.

The data we or third parties collect automatically may include personal information and/or statistical data that may not identify you personally; however, we or third parties may maintain, combine, or associate it with personal information collected in other ways or received from third parties. We and/or third parties use this information to (i) enhance the performance and functionality of the Digital Properties and/or Services; (ii) personalize your experience with the Digital Properties and/or Services, understand how you use the Website, maintain a persistent session, and improve and further develop the Digital Properties and/or Services; and (iii) serve targeted and other advertising, and provide custom experiences, across other sites, apps, online services, digital properties and devices, measure how the ads perform, and for analytics purposes.

The Tracking Technologies used on the Digital Properties and Services include the following, among others:

1. Cookies: Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. In addition to collecting information, we use cookies to help us authenticate users, provide content of interest to you, analyze which features you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. For information regarding your choices regarding Cookies, please see the “Your Choices” section of this Privacy Policy.

2. Identity Resolution and Deanonymization: We may use third-party identity resolution services (including, but not limited to, Retention.com) to recognize you when you visit our Digital Properties. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email address. We (or service providers on our behalf) may then send communications and marketing to that email address.

3. Sensitive Data Exclusion: We do not utilize identity resolution technologies on pages of our Website where you are asked to input Sensitive Financial Information (such as your net worth, specific account balances, or Social Security Number). Identity resolution is limited to general site navigation and marketing content.

4. Local Storage Technologies: We may use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

5. Web Beacons: We use Web beacons, also known as pixel tags or clear GIFs, to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

6. Third Party Sites: When access to the Digital Properties and/or Services is made available to you through third-party sites, please be aware that these other sites maintain their own policies regarding Tracking Technologies and the collection and use of information. You are responsible for reviewing those policies.

   1. Google Tag Manager: Our Website uses Google Tag Manager which is a solution operated by Google LLC. Google Tag Manager allows website tags to be managed through an interface. Google Tag Manager implements the tags and is a cookie-less domain and does not collect any personal information. Google Tag Manager triggers other tags that may collect personal information under certain circumstances. However, Google Tag Manager does not access this information. Any cookies or tracking disabled at domain or cookie level will remain disabled even when implemented with Google Tag Manager.
      
      

7. Information obtained from third-party analytics services

We may use one or more third-party analytics services to evaluate your use of the Digital Properties and Services, compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Digital Properties and/or Services you visit, number of links clicked while on the Website or Services, search terms and other similar usage data), and analyze performance metrics. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using any of the Digital Properties and/or Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Digital Properties and Services.

Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience and we will endeavor to update it diligently. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics.

8. How We Use and Share Your Information

We may use and share your information as set forth below:

• To provide the Digital Properties and Services;

• To onboard you as a client for the Services;

• When you use the Investment/Brokerage Services, for identity verification, credit, AML, KYC checks or other due diligence efforts;

• To provide Services, including servicing, maintaining, protecting, and processing transactions in your accounts on the Platform and Services, including Investment Account;

• To solicit your feedback, inform you about our products and services and those of our third-party marketing partners;

• To monitor, support, analyze, and improve the Digital Properties and Services;

• To fulfill your requests for information regarding new or improved products and services;

• To engage research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;

• To protect the safety and security of our Digital Properties, Services and our customers;

• To RIAs that participate in our Zoe Advisor Network that we match to you;

• To third-party contractors and service providers that provide services to us in the operation of our business and assistance with the Digital Properties and/or Services, such as technical support, IT and cloud hosting, payment processing, identity resolution and data appending, customer relationship management, email marketing, analytics services, and fraud detection;

• To create and disclose aggregated, anonymous, user statistics and other information to (i) affiliates, agents, business partners, and other third parties; (ii) describe the Services to current and prospective business partners; and (iii) other third parties for lawful purposes;

• To share some or all of your information with our parent company, subsidiaries, affiliates or other companies under common control with us;

• To fulfill our legal and regulatory requirements;

• To comply with applicable law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

• To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets;

• To audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• To prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and

• Otherwise, with your consent.
  
  

We will take reasonable measures (e.g., by contract) to require that any party receiving any of your personal information from us, including for purposes of providing the Services undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by applicable law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.

9. Aggregated and Anonymized Information

We may aggregate, de-identify, and/or anonymize information we collect or receive through the Digital Properties and Services. This includes information from or about prospective clients, clients, Authorized Users, RIAs (and their investment adviser representatives), financial advisors, vendors, service providers, and any other users. When we do this, we remove or alter details so that the information no longer identifies you or any other individual and cannot reasonably be linked to you (“Aggregated/Anonymized Information”).

Aggregated/Anonymized Information is not personal information, and we may use, disclose, share, and publish it for any lawful purpose. For example, from time to time we analyze investing-related and other financial topics using anonymized or summarized insights from our users, and we may publish those findings — or share them with external publishers — as research reports, articles, or blog posts. We maintain such information in de-identified form and will not attempt to re-identify it except as permitted by applicable law, and we require recipients to do the same.

10. Your Choices

• Update Information: If the personal information we have for you changes, you may correct, update, or delete it by contacting us as set forth in the “Contact Us” section of this Privacy Policy. You may correct, update, or delete some of your personal information directly in your account on the Zoe Wealth Platform. We will use commercially reasonable efforts to process all such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. Additionally, we will retain and use your information (or copies thereof) as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

• Marketing Communications: You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing emails. Please note that you cannot opt out of receiving transactional e-mails.

• Cookie Management: Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies or other Tracking Technologies, the Website, Services and the Zoe Wealth Platform may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

• Identity Resolution Opt-Out: You may opt out of having your anonymous browsing activity associated with your email address by our identity resolution partners by visiting https://app.retention.com/optout.

• Do Not Sell or Share / Targeted Advertising Opt-Out: If you are a California resident (or a resident of another U.S. state whose privacy law provides this right and applies to the relevant information), you may opt out of the “sale” or “sharing” of your personal information and of its use for cross-context behavioral (targeted) advertising. You can exercise this right using the methods described in the “Notice to California Residents” section and by broadcasting an opt-out preference signal, such as the Global Privacy Control, which we honor as described in the “Do Not Track” section. Our sharing of nonpublic personal information in connection with our financial products and services, and your related opt-out rights, are described in our Regulation S-P Privacy Notice.
  
  

You will need to apply these opt-out settings on each device from which you wish to opt-out. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

11. How We Protect Your Information

We take commercially reasonable security measures to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. Please note that although we employ industry-standard security measures to safeguard the security of your information, no transmissions made on or through the Internet are guaranteed to be secure. Therefore, we cannot ensure the absolute security of any information you transmit to us, and you use our Digital Properties and/or Services and provide us with your information at your own risk.

Consistent with our obligations under the SEC’s Regulation S-P, we maintain a written information security program that includes administrative, technical, and physical safeguards reasonably designed to (i) ensure the security and confidentiality of customer records and information, (ii) protect against any anticipated threats or hazards to the security or integrity of those records and information, and (iii) protect against unauthorized access to or use of those records or information that could result in substantial harm or inconvenience to any customer. We also maintain a written incident response program reasonably designed to detect, respond to, and recover from unauthorized access to or use of customer information. If we determine that an incident involving your sensitive customer information has occurred or is reasonably likely to have occurred, we will notify you as soon as practicable, and within the time and in the manner required by applicable law.

12. Retention of Your Information

We will retain your personal information for as long as it serves the purpose(s) for which it was initially collected, as stated in this Privacy Policy or subsequently authorized. Once the applicable retention period for a given type of data has expired, we may, at our discretion and in accordance with applicable laws, delete or securely destroy the data, or continue to retain it if necessary to comply with legal, accounting, or reporting obligations, enforce our agreements, or resolve disputes. You may request the deletion of your personal information at any time by contacting us at support@zoefin.com. Upon receiving such a request, we will take reasonable steps to delete your personal information from our records, unless retention is required to comply with legal obligations, resolve disputes, or enforce our agreements.

13. External Sites

The Digital Properties and/or Services may contain links to third-party websites (“External Sites”). These links are provided solely as a convenience to you and not as an endorsement by us of the content on such External Sites. The content of such External Sites is developed and provided by others. You should contact the website administrator or webmaster for those External Sites if you have any concerns regarding such links or any content located on such External Sites. We are not responsible for the content of any linked External Sites and do not make any representations regarding the content or accuracy of materials on such External Sites. You should take precautions when downloading files from all websites to protect your computer from viruses and other destructive programs. If you decide to access linked External Sites, you do so at your own risk.

14. Important Notice to All Non-U.S. Residents

Our Digital Properties, Services and servers are located in the United States. If you are located outside of the United States, please be aware that your information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Digital Properties and/or Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.

15. Do Not Track

As discussed above, third parties such as analytics providers may collect information about your online activities over time and across different websites when you access or use the Digital Properties and/or Services. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. Separately, certain U.S. state privacy laws require businesses to honor opt-out preference signals. Where applicable law requires it, we recognize and honor the Global Privacy Control (GPC) and other opt-out preference signals sent by your browser or device as a valid request to opt out of the “sale” or “sharing” of your personal information, including for cross-context behavioral (targeted) advertising, for the browser or device from which the signal is sent. Because there is still no uniform industry standard for legacy “Do Not Track” browser settings, we may not respond to those particular settings except where applicable law requires us to treat them as an opt-out. For more information about your opt-out rights, see the “Notice to California Residents” section below.

16. Notice to California Residents

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at support@zoefin.com. 

California Consumer Privacy Act (CCPA/CPRA). To the extent we act as a “business” and process “personal information” that is not exempt under the Gramm-Leach-Bliley Act (GLBA) or another applicable exemption, the following applies to California residents. Personal information that we collect and process in connection with a financial product or service, and other nonpublic personal information governed by the GLBA and the SEC’s Regulation S-P, is described in our Regulation S-P Privacy Notice and is not subject to this section.

Your rights. Subject to certain exceptions, California residents have the right to: (i) know and access the personal information we have collected about them; (ii) request deletion of their personal information; (iii) correct inaccurate personal information; (iv) opt out of the “sale” or “sharing” of their personal information, including for cross-context behavioral (targeted) advertising; (v) limit our use and disclosure of their sensitive personal information; and (vi) not receive discriminatory or retaliatory treatment for exercising these rights.

Sale or sharing of personal information. We do not sell your personal information for money. However, our use of cookies, identity resolution, and similar Tracking Technologies to deliver targeted advertising and to associate your online activity with your email address may constitute a “sale” or “sharing” of personal information under the CCPA/CPRA. You may opt out of this activity at any time by (a) using the “Do Not Sell or Share My Personal Information” and “Limit the Use of My Sensitive Personal Information” links on our Website zoefinancial.com, and (b) broadcasting an opt-out preference signal, such as the Global Privacy Control, which we honor as described in the “Do Not Track” section above.

Exercising your rights. To submit a request, contact us at support@zoefin.com or through the request method described on our Website zoefinancial.com.  We will verify your request as required by law, and you may use an authorized agent to submit a request on your behalf.

17. Other U.S. State Privacy Rights (Connecticut and Montana)

Several other U.S. states have enacted comprehensive consumer privacy laws. Many of these laws exempt financial institutions, like us, that are subject to the Gramm-Leach-Bliley Act (GLBA), or exempt the personal information we collect under the GLBA. Connecticut and Montana, however, have narrowed their exemptions so that their privacy laws may apply to personal information we process about their residents that is not subject to the GLBA (for example, certain website and marketing information). This section applies to residents of Connecticut and Montana with respect to such non-exempt personal information.

Your rights. Subject to certain exceptions, and to the extent the applicable state law and its thresholds apply to us, residents of Connecticut and Montana have the right to: (i) confirm whether we process their personal data and access that data; (ii) correct inaccuracies; (iii) delete personal data; (iv) obtain a portable copy of their personal data; and (v) opt out of (a) the sale of their personal data, (b) targeted advertising, and (c) certain profiling. You may also appeal a decision we make regarding a privacy request, as permitted by applicable law.

Exercising your rights. You may opt out of targeted advertising and the sale of personal data, including by broadcasting an opt-out preference signal such as the Global Privacy Control, which we honor as described in the “Do Not Track” section. To submit any other request, contact us at support@zoefin.com or through the request method described on our Website zoefinancial.com. We will respond to and verify your request as required by applicable law.

18. Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at support@zoefin.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

19. About Children

We do not knowingly collect or receive personal information from children under the age of 18 through the Digital Properties and Services. If you are under the age of 18, please do not provide any personal information to us. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any personal information through the Digital Properties and Services, or any other web site without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us at support@zoefin.com, and we will endeavor to delete that information from our databases.

20. Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Digital Properties and Services as soon as they go into effect. By accessing or using any Digital Properties and/or Services, after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

21. Contact Us

If you have any questions about this Privacy Policy or to report a privacy issue, please contact us in one of the following ways:

Email: support@zoefin.com 

(Please include “Privacy Compliance Officer” in the subject line of any correspondence regarding data security or Regulation S-P inquiries.)

Or write to us at:

Zoe Financial Inc.

666 Third Ave, 6th Floor

New York, NY, 10017

Telephone: 646 680 9244