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Privacy Policy

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April 2024


Maintaining the confidentiality of your personal information is very important to us at Beanstox Inc.  (“Beanstox”). This Beanstox Privacy Policy (the “Privacy Policy”) is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide to Beanstox by accessing our online platform (the “App”) or the Beanstox website (the “Website,” together with the App, the “Platform”) or otherwise engage with Beanstox. Please read this entire Privacy Policy before using or submitting information to the App or the Website.

By accessing the App or the Website you are agreeing to the terms of our Privacy Policy.

Information We Collect
Beanstox collects nonpublic personal information and other types of personal information about you as a user of our Platform, either as a visitor or as a client (“Personal Information”). Depending on the nature of your relationship with Beanstox, the categories of Personal Information we collect about you may differ. 

Personal Information from Visitors Personal Information collected from visitors and clients may include, but is not limited to:

  • Personally identifiable information that you input on the Platform, such as your name, address, e-mail address, phone number, and date of birth.
  • Device related information (including browser information and Internet Protocol (IP) addresses).
  • Server log information (including the date and time of your visit, time spent on the Platform, browsing activity, and any site from which you linked to the Platform).


Additional Personal Information from Clients
If you become a client of Beanstox, the additional Personal Information collected includes, but is not limited to:

  • Your full legal name, permanent address, gender, social security number or tax identification number, and residency/citizenship status.
  • Your income, net worth, investment goals, financial experience, professional experiences and affiliations, tax information, and other information required by applicable law.
  • Your client account information, such as the username, account password for you Beanstox account.
  • Financial and transaction-related information, such as account numbers, bank information, transaction history, and investable assets.


Third-Party Service Providers
We use several third-party service providers who might collect Personal Information from you.

Plaid Technologies, Inc. (“Plaid”) collects information about your data from you and from financial institutions when you become a client and need to create and fund your Beanstox account. By using our Platform, you grant Beanstox and Plaid the right, power, and authority to act on your behalf to access and transmit your Personal Information as well as account information maintained by third-party financial institutions. This information may include account balances, transactions and holdings from the third-party financial institutions. You acknowledge and agree that the information you provide to Plaid though Beanstox will be treated by Plaid in accordance with Plaid’s privacy policy which is available at https://plaid.com/legal/. By choosing to link your financial institution account to aggregate and analyze Personal Information, you expressly authorize and direct Beanstox and Plaid, on your behalf, to electronically retrieve Personal Information.

DriveWealth, LLC (“DriveWealth”) provides brokerage and custody services for Beanstox and its clients. When opening a Beanstox account you enter into a brokerage agreement with DriveWealth, a registered broker-dealer.  By using the Platform, you acknowledge and agree that DriveWealth will collect, and have access to, Personal Information. You acknowledge and agree that the information you provide to DriveWealth will be treated by DriveWealth in accordance with DriveWealth’s privacy policy which is available at  https://drivewealth.com/.

Information We Use and Share
We do not sell your Personal Information and we do not disclose it to any unaffiliated third party except as necessary to process and service transactions requested or authorized by you as a client of the Platform, or as required by law. For example, we may share Personal Information we collect about you with relevant third-party service providers worldwide including, but not limited to, fund administrators, auditors, and customer relationship management partners, as appropriate, who must have this information for us to deliver our services to you. The service providers must keep your information confidential and cannot use it for their own purposes unrelated to the services we provide to you, such as for marketing their own products or services. We may share this Personal Information with our legal counsel as we deem appropriate and with regulators. We may disclose Personal Information about you at your request, or as otherwise required by law. We may make full use of all Personal Information acquired through the App or Website that is not in personally identifiable form. Except as otherwise stated, we may use your Personal Information to improve or modify the content of the Website, to customize the Website to users’ preferences, to communicate information to you, for marketing and research purposes, and for the purposes specified in this Privacy Policy or otherwise permitted by law. 

We also use Personal Information to provide our services, including to maintain and improve our Platform and services to you, and to inform you about our products and services.

We may also use or share Personal Information as described below.

  • In an ongoing effort to better understand our users, and our products and services, we may analyze Personal Information in aggregate form in order to operate, maintain, manage, and improve the Platform, our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
  • We may share some or all of your Personal Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us who must have this information for us to deliver our services to you. These related parties must keep your information confidential and cannot use it for their own purposes, including the marketing of their products and services, unrelated to the services we provide to you.
  • As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Personal Information may be part of the transferred assets.

 
Opt-out Information
Federal law provides you with the right to limit (i) the sharing of your Personal Information with affiliates for their own business purposes, (ii) parents and affiliates of Beanstox from using your Personal Information to market to you, and (iii) the sharing of your Personal Information to unaffiliated third parties to market to you.  However, Beanstox does not knowingly collect or share Personal Information for the purpose of (iii) above. Accordingly, your ability to opt-out of our use of your Personal Information is limited. Note that you cannot opt out of administrative communications, such as emails and SMS that contain account information or notify you regarding activity in, or changes to, your account, or contain updates to our terms and conditions and other legal documents.

Passive Information Collection
As you navigate through the Website, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses, cookies, Internet tags, Facebook pixels, and navigational data collection. The Website may use your IP address, which is a number assigned to your computer by your Internet service provider, so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). We may use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and to administer and improve the Website.

Analytics Services
We use third-party analytics tools, including “Google Analytics” (such tools collectively referred to as “Analytics Services”) to collect information about the usage of the Website. The Analytics Services collect information about how often users visit the Website, what pages they visit when they do so, and what other websites they used prior to coming to the Website, among other information. We use the information we get from these Analytics Services to improve the Website and our services.

The Analytics Services collect the IP address assigned to you on the date you visit the Website, along with other anonymized information (e.g., browser type and type of device used to visit the Website), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to the Website is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Analytics Services with personally identifiable information.  

You can prevent Analytics Services from recognizing you on return visits to this site by disabling cookies on your browser. You can opt-out of Analytics Services by installing the Google Analytics Opt-out Browser Add-on.

About Cookies   
A “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. “Session” cookies are temporary bits of information that are erased once you exit your web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on website and to collect aggregate statistical information. “Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of a website visitors find most valuable, and customizing the website based on your preferences. The Website uses both session and persistent cookies. When a new registration is recorded on the Website, the information is sometimes recorded and stored by a third-party via a cookie. Although third parties manage the use of these technologies, the information is only used for the purpose of managing Beanstox’s marketing materials and the Website. Third parties are contractually obligated to keep the information confidential and are prohibited from using it for any purpose not expressly permitted by Beanstox.  

About Internet Tags
“Internet tags” (such as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell a website server information such as the IP address and browser type related to the visitor’s computer. Although we currently do not intend to use Internet tags on the Website, we may do so in the future.

About Facebook Pixel
The Website uses Facebook pixels, which are code that is placed on websites. It allows the Website to track conversions from Facebook ads, optimize ads based on collected data, and build targeted audiences for marketing for visitors who have already taken action on the Website.

About Log Files
The Website uses “navigational data” (“log files,” “server logs,” and “clickstream” data) that are used for system management, to improve the content of the Website, market research purposes, and to communicate information to visitors.

Information Security
We take reasonable steps to protect your personally identifiable information as you transmit your information from your computer to Beanstox and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100 percent secure or error-free. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features for access to the App or to the Website, it is your responsibility to safeguard them. Within Beanstox, access to information about you is restricted to those employees who need to know the information. We maintain physical, electronic and procedural safeguards to protect your Personal Information. Our employees are trained to follow our procedures to protect your privacy and are instructed to access information about you only when they have a business reason to obtain it.  

Links to Other Websites
For your convenience, the App and Website may contain links or references to other websites, applications, and social media accounts which are not operated by Beanstox. Please be aware that we do not control other websites, applications, and social media accounts, and, in all cases, this Privacy Policy does not apply to those other websites, applications, and social media accounts. We encourage you to read the privacy policy of every website you visit. We are not responsible in any way for the content of such other websites, applications, and social media accounts.


Children
Our service is not directed towards anyone under the age of 18. If we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Beanstox or provided us with personally identifiable information, please contact us at [email protected].

Access, Change or Delete Your Personal Information
Once you have opened an account with Beanstox, you can access your profile, review the information that is stored, and revise or delete that information. If you have any problems, you may also contact us at [email protected]. In order to delete any Personal Information, you will have to provide enough information to identify your account and prove that you are the owner of the account.  We may retain residual information related to your account, as well as any data related to your transactions and investments, in accordance with applicable laws.

Former Clients
This Privacy Policy applies to former clients. If you no longer have an account with Beanstox, you may request that we delete Personal Information associated with your account. However, certain Personal Information associated with your account may be retained after your account is closed in accordance with Beanstox’s records retention policy if required or permitted by applicable law.

Vermont Residents
We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by opening a Beanstox account, please contact us at [email protected]. Please note, however, that we will not be able to provide you with services through Beanstox without the ability to share this financial information.

California Residents
This section of the Privacy Policy applies to California residents for purposes of the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and the regulations issued under it. Accordingly, this section addresses the specific requirements of the CCPA and should be read together with the other sections of the Privacy Policy. Any terms defined in the CCPA have the same meaning when used in this section and may differ from what those terms mean when we use them in other sections of the Privacy Policy.  Specifically, as used in this section, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. Personal information does not include aggregate or deidentified information or publicly available information.

The CCPA provides specific privacy rights to California residents, including the right to receive a privacy notice and certain rights you may choose to exercise relating to your personal information. If your relationship and interactions with Beanstox consist solely of personal financial services, the personal information collected and processed about you is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and therefore your CCPA request will not be honored by Beanstox.

Your Rights under the CCPA

Subject to the above, if you are a California resident, you may ask Beanstox to disclose what personal information it has about you and what it does with that information, to delete your personal information, to direct Beanstox not to sell or share your personal information, to correct inaccurate information that Beanstox has about you, and to limit Beanstox’s use and disclosure of your sensitive personal information:

  • Right to know: You can request that Beanstox disclose to you: (1) the categories and/or specific pieces of personal information it has collected about you, (2) the categories of sources for that personal information, (3) the purposes for which Beanstox uses that information, (4) the categories of third parties with whom Beanstox discloses the information, and (5) the categories of information that Beanstox sells or discloses to third parties. You can make a request to know up to twice a year, free of charge.
  • Right to delete: You can request that Beanstox delete personal information collected from you and tell its service providers to do the same, subject to certain exceptions (such as if Beanstox is legally required to keep the information).
  • Right to opt-out of sale or sharing: You may request that Beanstox stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control. Beanstox cannot sell or share your personal information after it receives your opt-out request unless you later authorize it to do so again.
  • Right to correct: You may ask Beanstox to correct inaccurate information that it has about you.
  • Right to limit use and disclosure of sensitive personal information: You can direct Beanstox to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

You also have the right to be notified, before or at the point Beanstox collects your personal information, of the types of personal information Beanstox is collecting and what it may do with that information. Generally, Beanstox cannot discriminate against you for exercising your rights under the CCPA. Beanstox cannot make you waive these rights, and any contract provision that says you waive these rights is unenforceable.

Exercising Your Rights under the CCPA

If you wish to make a CCPA request, please submit your request to Beanstox Inc. via email at [email protected].

If you have an account at Beanstox, you may be requested to provide your account information to facilitate verification of your CCPA request.  If you do not have an account at Beanstox, you will be asked to provide personal information to verify your identity.

Authorized Agent
You may designate someone as an authorized agent to submit your CCPA request and act on your behalf.  Authorized Agents will be required to provide proof of their authorization. We may also require that you verify your identity with us before processing your CCPA request made through your authorized agent.

International Visitors
Our App and Website are hosted in the United States. If you are an international visitor, you should note that by providing your Personal Information, you are: (i) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy.

Changes to Our Privacy Policy
We reserve the right to change this Privacy Policy in the future at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. Any changes to the Privacy Policy will be effective upon posting the modified version on the App or Webb, or as indicated on the posting.

Questions
For questions about our Privacy Policy, or for additional copies of this Privacy Policy, please contact Beanstox Inc. via email at [email protected].