Our Commitment to You

Datalign Advisory, Inc. (“Datalign”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Datalign (referred to as “we”, “our”, and “us” throughout this notice) makes reasonable efforts to protect the security and confidentiality of the personal information we have and to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.

Details of our approach to privacy and how your personal nonpublic information is collected and used are set forth in this privacy policy.

This site privacy policy (“Privacy Policy”) explains how Datalign collects, uses, shares, and safeguards information about you when you engage with Datalign, or you use the datalignadvisory.com website and any associated content and materials available in connection with the website (collectively, the “Site”).

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on the Site and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy. If Datalign determines that such changes materially affect your privacy rights, we will provide additional notice to you. Additionally, we strive to send you notice of our privacy policy at least once every twelve months.

Collecting Your Information

We may collect information about you in two main ways:

1. Information You Provide to Us

Personal information you choose to provide, such as your name, age, phone number, location, and financial information.

2. Information We Collect About You

We may collect information about you in a variety of ways but generally speaking it is done either through (1) you completing our web forms or (2) you visiting our websites. The types of information we may collect include, but are not limited to:

Information You Provide To Us

This is personal information you choose to provide in connection with completing an online form, providing content on the Site, or other activities in which you participate on the Site, such as your name, age, phone number, location, and financial information.

Information We Collect About You

Information our servers automatically collect when you visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. If you access the Site from a mobile device, information about the type of mobile device you use.

In order to collect this information, the Site may use cookies, web beacons, and other tracking technology, depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience. If you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information. Aggregate cookie and tracking information that does not directly identify you may be shared with third parties. We do not control these third parties’ tracking technologies or how they may be used. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we’ve collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies.

Additional Information

Datalign does not collect any sensitive personal data on its users, nor does it collect any data from third parties. If a user completes a web form questionnaire, the user will have a lead identifier tagged to their account. The lead ID (“Lead ID”) is intended to be pseudonymized when used internally by Datalign and de-anonymized when provided externally by Online Partners.

Using Your Information

We may use the information that you provide to us to match you with a financial advisor or for our Online Partners to attribute revenue to Datalign appropriately. Any information collected about you via the Site may be used to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; generate a personal profile of you to make future visits to the Site more personalized; perform the functions and services you request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; to support our customers and their interactions with you through our Services; market our services (and those of third parties) to you that we believe may be of interest to you; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.

Sharing Your Information

We may share your information with third parties that perform services for or on our behalf this includes:

• When you provide authorization for us to share it with a financial advisor

• To perform analytics on website and/or web form engagement

• When it is shared as part of a transfer of assets

• For security and fraud purposes

• When we are required by law to share it.

Match With a Financial Advisor

Datalign shall only provide web form submitted answers with a financial advisor if you provide your express consent. Otherwise, Datalign does not provide any personal information.

Analytics

We may allow selected service providers or processors, such as Hotjar, to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Transfer of Assets

If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.

Targeted Advertising

Datalign does not sell or share your data in exchange for monetary consideration or value.

Security and Fraud

We allow third parties such as Cloudflare to receive personal information from our users to provide both security and fraud protection to Datalign. We do not control these third parties or how it is used. For more information on how Cloudflare uses your personal information, please visit their privacy policy here: https://www.cloudflare.com/privacypolicy/

Required by Law

We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of datalignadvisory.com or others, as we deem appropriate.

Attribution

Datalign allows third parties to host our web form on their website domain (“Partner Websites”). For the purposes of attributing revenue and analysis, Partner Websites receive your LeadID along with certain attribution features. Datalign does not provide any identifiable personal information while doing this and the LeadID is not intended to be re-identified by third by our Partner Websites. If you have reason to believe a Partner Website has violated this section, please contact us using the information below.

Security of Your Information

While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site. To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.

Policy for Children

We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.

Links to Other Websites

The Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.

Submitting Information From Outside the U.S.

We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the Website and Services may be stored and processed in the United States or any other country in which our vendors or we maintain facilities. Although we do not actively block or monitor visitors from other countries, the Website is directed only at visitors from the U.S. As such, this Privacy Policy is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). Datalign will apply the applicable laws of the U.S., including as embodied in this Privacy Policy in place of data protections under your home country’s law. That is, you freely and unambiguously acknowledge that this Privacy Policy, not your home country’s laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.

Exercise Your Privacy Rights

Datalign takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Datalign to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:

• The Right to Know - You have the right to request that Datalign disclose the personal data that Datalign has collected about you

• The Right to Amend - You have the right to correct any information that Datalign stores about you

• The Right to Delete - You have the right to request that Datalign delete information that it maintains about you, subject to certain exceptions

• The Right to Opt Out Of Your Personal Information Being Sold or Shared - You may opt-out of Datalign sharing or selling your information.

In order to exercise any of the rights detailed above, privacy@datalignadvisory.com. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Datalign. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting privacy@datalignadvisory.com

Retention Period

Datalign shall only store personal information for as long as it is required. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on (1) the nature of our relationship with the data subject and (2) any legal obligations we are bound to fulfill.

Contact Us

If you have questions or comments about this Privacy Policy, please send us an email at privacy@datalignadvisory.com. If you prefer, you may also contact us via physical mail at:

Datalign Advisory, Inc.
One Kendall Square, Suite B2102
Cambridge MA 02139

California Consumer Privacy Act (CCPA) Notice

The California Consumer Privacy Act (“CCPA”), which provides California Consumers certain rights regarding their Personal Information (“PI”) as those terms are defined in the CCPA, became effective on January 1, 2020. As of that date, the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law. In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection for data that may be subject to the CCPA (“CCPA Notice”). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions. We may collect and share the following personal information that may be subject to the CCPA for the following purposes: