Last modified: February 9, 2020
a. The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the DYNAMIC MAPPING Application (the “App“); and
b. Our practices for collecting, using, maintaining, protecting, and disclosing that information.
1.2 This Policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.
1.3 This Policy DOES NOT apply to information that:
a. We collect offline or on any other Company apps or websites, including websites you may access through this App; or
b. You provide to or is collected by any third party. See Third-Party Information Collection Section for more information.
1.4 Our websites and other apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. Certain details of this Policy may depend on whether you: are dealing with us in connection with a financial service professional that we have trained in the DM process, you are a financial professional trained in the DM process, or you are accessing this App on your own without assistance from a financial service professional. We are the super-administrator of the App, but the financial professionals who have undergone DM training will be sub-administrators who may limit our access to user information by creating a password, and choosing the appropriate setting in the App.
2. Children Under the Age of 16
2.1 The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
2.2 California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.
3. Information We Collect and How We Collect It
3.1 We may collect information from and about users of our App in any or all of the following ways:
a. Directly from you when you provide it to us.
b. From your financial service professional unless he/she prevents us from accessing your information. We will not be collecting any data from financial professionals if they choose to lock us out by applying a password.
c. Automatically when you use the App.
3.2 Information You Provide to Us. When you download, register with, or use this App, we may ask you to provide information:
a. By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information“); and
b. That is about you but individually does not identify you, such as: planned retirement age and date, combined accumulated savings for retirement, combined monthly contributions for retirement, monthly pensions, monthly social security amount, other monthly retirement income, and the age at which income began and is anticipated to end.
3.3 Specific Types of Information and How You Might Provide Such Information. Specifically, this information includes any or all of the following:
a. Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App and requesting further services. We may also ask you for information when you report a problem with the App.
b. Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
c. Your responses to surveys that we might ask you to complete for research purposes.
d. Your search queries on the App.
e. Information related to retirement plans, such as life expectancy, and retirement age.
3.4 Automatic Information Collection and Tracking. When you download, access, and use the App, it may use technology to automatically collect:
a. Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, and the resources that you access and use on or through the App.
b. Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number.
c. Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
3.5 Your Options. If you do not want us to automatically collect this information do not download the App or delete it from your device. In addition, DM trained professionals may limit our access to such DM trained professionals’ customer information by creating a password and selecting the appropriate mechanisms through the App. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
3.6 Information Collection and Tracking Technologies. We may automatically collect your information by using web beacons, (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
3.7 Third-Party Information Collection
a. When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include any or all of the following:
- Your mobile device manufacturer.
- Your mobile service provider.
- DM trained professionals, if you are an individual and you have provided permission in the App.
- Individuals interested in professional financial services, if you are a DM trained professional.
b. These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
c. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
d. In addition, DM trained professionals may collect information from you after you consent to our providing your personal information to such DM trained professionals. We do not control the information that these third parties collect. Such third-party DM trained professionals may limit our access to your personal information, or to any information you enter into the App.
4. How We Use Your Information
4.1 We use information that we collect about you or that you provide to us, including any personal information, to do any or all of the following:
a. Provide you with the App and its contents, and any other information, products or services that you request from us.
b. Fulfill any other purpose for which you provide it.
c. Give you notices about your account, including expiration and renewal notices.
d. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
e. Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
f. We may create anonymous data records from personal information by excluding information (such as your name) that make the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our App and our services and improve site navigation.
g. To connect you to a third-party DM trained professional after you have consented to this sharing of information.
4.2 The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to do any or all of the following:
a. Estimate our audience size and usage patterns.
b. Store information about your preferences, allowing us to customize our App according to your individual interests.
c. Speed up your searches.
d. Recognize you when you use the App.
4.3 We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you after obtaining your consent to do so. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
4.4 If you provide feedback on the App to us, we may use such feedback for any purpose, provided we will not associate such feedback with your personal information. Company will collect any information contained in such communication and will treat the personal information in such communication in accordance with this Policy.
5. Disclosure of Your Information
5.1 We may disclose aggregated information about our users, and information that does not identify any individual without restriction. We also require third parties we share data with to provide the same or equal protections for the data we share as required by this Policy and the applicable App Store.
5.2 In addition, we may disclose personal information that we collect or you provide to any or all of the following:
a. Our subsidiaries and affiliates.
b. Contractors, service providers, and other third parties we use to support our business.
c. A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred.
d. Third parties to market their products or services to you if you have consented to these disclosures. We use commercially reasonable efforts to encourage these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
e. To fulfill the purpose for which you provide it. For example, if you give us an email address to contact us on the App, we will transmit the contents of that email and your email address to a DM trained professional to contact you regarding their services.
f. For any other purpose disclosed by us when you provide the information.
g. With your consent.
h. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
i. To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection, as applicable.
j. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Your Choices About Our Collection, Use, and Disclosure of Your Information
6.1 We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information. If you do not want us to use your email, or other contact information, to promote our own or third-party products or services, you can opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to firstname.lastname@example.org.
6.2 We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.
7. Accessing and Correcting Your Personal Information
7.1 You can review and change your personal information by logging into the App and visiting your account profile page. You may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us.
7.2 You may request deletion of your personal information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Keep in mind, we may not be able to delete your personal information except by also deleting your user account.
7.3 Proper access and use of information provided on the App is governed by our End User License Agreement [LINK TO EULA].
8. California and Delaware “Do Not Track” Disclosures
California and Delaware law require Company to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, Company adheres to the standards set out in this Policy and does not monitor or follow any Do Not Track requests.
9. USERS OUTSIDE OF THE UNITED STATES
This App is not intended for users outside of the United States. DO NOT USE THIS APP IF YOU ARE LOCATED, OR IF YOUR PERMANENT RESIDENCE IS, OUTSIDE OF THE UNITED STATES.
10. Data Security
10.1 We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and is encrypted at-rest and in-transit. However, no system is entirely without risk and we cannot guarantee the security of your data.
10.2 The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential and for using a password different from that used for other websites or applications. We ask you not to share your password with anyone.
10.3 Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
11.2 The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Policy to check for any changes.
12. Complaints, Changes and Contact Information
12.1 If you believe Company has not adhered to this Policy, to ask questions or comment about this Policy and our privacy practices, or to withdraw consent that you have previously provided, please contact us at:
Real Intelligence LLC
14 Knollwood Drive
Fairfield, CT 06824
12.2 We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
BY SUBMITTING PERSONAL INFORMATION THROUGH OUR APP OR RELATED SERVICES, AND CLICKING THE I CONSENT BUTTON BELOW, YOU AGREE TO THE TERMS OF THIS POLICY AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY.