Last Updated and effective as of: December 12, 2017
Welcome to the website located at www.financialgym.com and related subdomains (the "Site"), owned and operated by The Financial Gym, LLC (“TFG,” "we," "us," or "our," as used in this Policy). This Privacy Policy explains how we collect, use and share information gathered from visitors to our Site ("you," "your, or "users" as used in this Policy). As used in this Policy, "Services" means the online financial profile and related services available through our Site. If you engage us to provide offline services, you should request details about how offline data is handled and stored. The policy below applies ONLY to Site visitors and users of the Services on our site.
What We Collect
We may collect information from you when you when you visit the Site and when you sign up for our members-only Portal, accessible through an emailed invitation containing a link from a TFG trainer, explained below. The trainer is someone who our clients have already had offline or other contact with.
When you visit the Site, we log and store your IP Address and technical information about your visit like your browser type and other common analytics information, such as Google Analytics ("Site Usage Information"). Our site does not place cookies at this time unless you use the Portal. Google analytics collects only non-identifiable demographic information about your Site visit.
When you use the Portal, we place a small piece of software referred to as a "cookie" on your computer to help us record your login ID and password. This cookie expires in 30 minutes if you do not check the "Remember Me" box when logging in. It expires after 2 weeks if you do check the "Remember Me" box. You can remove this and other cookies through your browser preferences menu, though the exact method varies depending on the type of browser you use. If you visit from a mobile device, we may reference your device identifier or other information about where your visit originated.
When you use the Portal, you will also create an account. We use "Account Information" to refer to the information you choose to associate with your account using the Portal, which may include: (1) the username email you provide and the password you identify, (2) personal information including your name, address, phone number, date of birth, (3) optional demographic information including race and/or ethnicity, gender, education, marital status and number ofdependents (4) employment information including employment status, industry and annual salary, and (5) details about additional incomes you may have.
You can also use the Portal to automate our collection and analysis of your bank transaction history by providing your online banking credentials and bank name for one or more online banking services from various banks, referred to in this policy as "Bank Account Information."
How We Use It
Usage Data helps us monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site, diagnose or fix technology problems, and otherwise plan for, improve and enhance our Site or our business operations. We may also track what online training sessions have been viewed on an aggregate basis or by an individual user. By using online coaching sessions, you agree we can track your video viewing history.
We may reference Account and/or Bank Account Information when you engage us for financial coaching services over the phone. The information gathered through our phone-based coaching sessions may include more detailed information about your assets and other types of accounts, liabilities, and expenses. We do not add this information to your online Account Information, but it is accessible to your coach. Your trainer, an approved coach who must be invited to our web platform by a TFG administrator, will invite you to our Platform. Please ask your trainer any questions you may have about how information collected offline is stored. While trainers are subject to contractual confidentiality obligations to TFG, TFG makes no representation or warranty regarding their backgrounds or qualifications.
Your Bank Account Information is used to coordinate our third party API services’ collection and transmission of your bank transaction history. This provider (referred to in this policy as our "Finance API Solution," is currently Plaid, and you can read about their data handling practices in Plaid’s terms of service and privacy policy here. Note that when you use their service to process payment transactions, you will agree to their terms to the extent applicable to you. Plaid is responsible for encrypting your Bank Account Information in transit and as it interacts with their API. TFG reserves the right to switch third party service providers.
Your Account Information, including Bank Account Information, is retained in either active or archived form once you create an account. We maintain this information because may users reactivate their accounts after a hiatus, but you can delete it by following the instructions below.
Sharing of Your Information
We share Account Information and Bank Account Information with our Finance API Solution to populate the Portal with your transaction history. We also use your Account Information to transmit consent forms and other contracts to you via HelloSign or another this party e-signature service, and to email you using third party email services.
We may share Usage Data with our third party service providers in the course of our operations in order to operate and maintain our Site. We may also engage third parties to help us improve our business, such as analytics providers, and such parties may have access to aggregate or individual Usage Data.
Account Information and Usage Information, as well as metadata relating to these about your use of the Site, may be shared with third party cloud services that provide us with hosting and other technical infrastructure. These entities are required by contract to keep your information confidential.
Third Party Sharing. In the ordinary course of our business we may also share Personal Information as follows:
Security of your Information
We care about the security of your information and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and, in some cases, share with our service providers. Because of the nature of our Site and Portal, we use Secure Socket Layer technology and HTTPS. Our third party Finance API Provider may encrypt transmission to your bank. IF YOU ARE UNCOMFORTABLE WITH THE TRANSMISSION OF THE INFORMATION DESCRIBED HEREIN, PLEASE DO NOT SUBMIT INFORMATION TO US THROUGH THE SITE OR PORTAL.
While we take reasonable precautions against possible security breaches, no website or internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss or other breach will never occur. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Your activity on the Site does not allow us to recognize or acknowledge Do Not Track signals, though our registration process and services are secured according to specific contractual promises. Do not transmit any sensitive or personal information using the Site other than as directed to create an account on the Platform.
Third Party Links
The Site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
Your California Privacy Rights
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.
Children
Minors under 18 are not permitted to use our Site and we do not intentionally collect information from minors under 13. If you believe we have collected any personal information from a child younger than 13 years of age, please notify us immediately at info@fingyms.com and we will do anything reasonably possible to remove that information from our systems.
Contact Us and Accessing Your Information
If you have any questions about our privacy practices, or if you wish to remove any of your personal information from our records please contact us at either:
The Financial Gym, LLCor
Note that we do not have identifying information on file for most users. We can only remove personal information actually in our possession.
If you do email us at info@fingyms.com and ask that we remove any information we have stored about you on our systems, we will do so within a reasonable time of receiving your request.
If we make a material (as determined in our sole discretion) update to this policy, we will attempt to notify you of such update via email, or within the Platform or Site.
Thanks for using The Financial Gym!