Beagle Financial Services
Last Updated: May 19, 2022
WHAT PERSONAL INFORMATION DO WE COLLECT?
When You sign up for Our periodic email newsletters, You provide Beagle with the following Personal Information: Your name and email address. From this newsletter request, We may also add You to Our email marketing list, but You will always be able to opt out. (See “Email Marketing” section below for details.)
When You create an account with Beagle to either become a Client or a Member, You will be required to register in order to gain access to certain Services, as defined in Our Terms and Conditions.
We will, therefore, collect from You, as a Client or Member, certain Personal Information, including, but not limited to, the following:
- Email address
- First name and last name
- Phone number
- Address, city, state, zip code
- Bank account information in order to pay for products and/or services within the Service
- Date of birth
- Social security number
- Information about Your financial status
- Usage data
We are required by law to collect and store this information to provide You with certain Services as further described in Our Terms and Conditions and related documents located on Our Website’s “Legal Page.”
Apart from registering to be a Beagle Client or Member and/or visiting Our Website, We may collect various other types of Personal Information if You or a friend engages with Beagle. We collect Your email address as part of Our customer referral service or if You access as a Visitor or subscribe (if applicable) to the Beagle Resources blog. We may also collect Personal Information if You enter it into Our live chat program (if applicable) or contact Us or otherwise give it to Us (e.g., in an email, phone call, or live chat with a member of Our customer support team). Further, We may collect information regarding Your browsing activity when You visit Beagle’s websites and actions You take within Your Beagle account while logged in to Your Beagle account as either a Client or Member.
WHAT OTHER PERSONAL INFORMATION IS COLLECTED BY US THROUGH OTHER THIRD-PARTY SOURCES?
We may collect Personal Information from “Other Third-Party Sources,” such as the following types.
- Data brokers from which We purchase data to supplement the data We collect.
- Social networks with which You interact.
- Partners that offer co-branded services, products, or programs.
- Publicly available sources, including data in the public domain.
WHAT PERSONAL INFORMATION IS USED WHEN YOU PURCHASE SERVICES?
Our Payment Processors
We use unaffiliated third parties to provide payment processing services that enable You to purchase products and services within Our Services (“Payment Processor(s)”).
If You wish to purchase a Beagle product or service, then You will be directed to a payment processing service webpage belonging to a Payment Processor, such as (for example) Stripe or Pay Pal. The applicable Payment Processor (not Us) will collect Personal Information (which may include Your credit card information and other financial-related information) from You in order to process Your payment for Your purchase.
We have no control over, and are not responsible for, any Payment Processor’s use of any of Your Personal Information collected through such payment processing service. These Payment Processors generally adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Payments through Bank Transfers
When You pay for one of Our products or services via a bank transfer, We may ask You to provide certain Personal Information to facilitate this transaction and to verify Your identity. Such information may include:
- Date of birth
- Passport or National ID card
- Bank card statement
- Other information linking You to an address
HOW DO WE USE OR SHARE YOUR PERSONAL INFORMATION?
We and Our “Third-Party Service Providers” (which means contractors and consultants We directly hire to help Us provide Services, but excludes all Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers and AWS), upon Our instruction and authorization, may use Your Personal Information:
● To respond to Your inquiries and fulfill Your requests, such as to send You newsletters or whitepapers.
● To set up and administer Your account when You become a client.
● To provide Our Services for You.
● To manage Your account and send administrative information to You, such as information regarding the Services and changes to Our terms, conditions and policies.
● To maintain Our Services to You, including providing You with customer service or support.
● To analyze, improve or enhance Our Services to You.
● To complete and fulfill Your purchase of Our products or services, including communicate with You regarding such purchases.
● To send You marketing communications about Beagle products and services that We believe may be of interest to You, subject to any choices You have expressed with respect to such communications.
● To personalize Your experience of the Services by presenting content, products and offers tailored to You.
● To request Your participation in any surveys and to administer such surveys. We may, if we decide to set up a survey, use the results of such surveys to understand user engagement, as well as for marketing purposes.
● For Our business and operations purposes, such as internal data analysis, audits, monitoring and protection of security and integrity of the data and systems supporting or operating Our Services; prevention of unauthorized intrusions, developing new products and services, enhancing, improving or modifying Our Services, identifying usage trends, determining the effectiveness of Our promotional campaigns and operating and expanding Our business activities.
Our Third-Party Service Providers (as referenced in this Section) do not track and collect information about Your online activities over time while You navigate to, from, and on the Website or through Our Services. They are not permitted to share or use Your Personal Information that We make available to them for any purpose other than to provide services to Us in order for Us to operate Our Website and provide Our Services.
In order to provide certain workplace services to employers or plan sponsors, such as retirement savings plan services, we may exchange any information received in connection with such services with the employer or plan sponsor or others they may authorize, such as an employer-selected investment professional. We may also share information, including but not limited to account positions, contributions, distributions, and cash flows, with a third-party financial institution that serves as a directed trustee to 401(k) plans serviced by Beagle.
We reserve the right to use, retain or disclose any information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud; and if such action We believe is necessary or appropriate: (a) to conform to the requirements of applicable law which may include laws outside Your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside Your country of residence; (c) to protect and defend the legal rights or property of Beagle, Our users and clients or other third parties; (d) enforce Our Terms and Conditions; or (e) in an emergency, to protect the health, safety or privacy of Our users, other persons or the general public.
We also reserve the right to disclose any information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
WHEN SHOULD YOU NOT SHARE PERSONAL INFORMATION WITH US?
Do not send Us, and do not disclose, any Personal Information or any other financial or other sensitive information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) in any email correspondence with Us.
WHAT “OTHER INFORMATION” DO WE COLLECT AND USE?
Other Information (aka Anonymous/Aggregated Information)
“Other Information” is any information that, in itself, does not reveal an individual’s specific identity and that does not directly relate to an identifiable individual, such as:
● Browser and device information.
● Information collected through cookies, pixel tags and other technologies.
● Demographic and other statistical information.
● Aggregated or anonymous information.
As part of this process, we may from time to time include, compile, or aggregate some of your Personal Information in certain data analyses, reports, insights or observations, or other interpretations of financial or investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it does not include any personally identifiable information. We may share such anonymized information in the form of research reports, blog posts or findings may be shared with external publishers or published by Us on financial topics of interest.
We use third-party analytics tools, including “Google Analytics” and “Amplitude Analytics” (such tools collectively referred to as “Analytics Tools”) to monitor and analyze the use of Our Services and collect such usage information. We use the information we get from these Analytics Tools to improve Our Services.
The Analytics Tools collects information about how often users and clients visit Our Website, what pages they visit when they do so, and what other sites they used prior to coming to this Website, among other information. These Analytics Tools also collect the IP address assigned to You on the date You visit this site, 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.
For example, Google, through Google Analytics, can track and reports website traffic, use the data collected to track and monitor the use of Our Services, and also share this data with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For example, You can prevent Google Analytics from recognizing You on return visits to this Website by disabling cookies on your browser. You can opt-out of Google Analytics by installing the “Google Analytics Opt-Out Browser Add-on.”
WHAT OTHER TECHNOLOGIES AND THIRD PARTIES AFFECT YOUR PRIVACY AND USE OF OUR SERVICES?
The following are ways that We may collect information from You about Your use of Our Services. Our Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers and AWS may use these methods as well, but their uses are governed by their own, respective privacy policies.
● Cookies and Pixels
A cookie is a small data/text file that is stored on a computer, mobile phone or other device and is used to identify the user or device and to collect information and access the internet. Pixels are small code blocks on a website that allows for another server to measure viewing of a webpage and are often used in connection with cookies.
We may store some Personal Information in a cookie and/or pixel, such as the site that You visited immediately prior to visiting Our Website and relevant financial information that allows Us to enhance Your user experience and for marketing purposes. Additionally, We may use a cookie and/or pixel to track visitors across various websites or devices to better customize Our marketing and advertising campaigns.
Cookies, pixels, and similar technologies are not required for Our Website functionality. You are not required to accept any cookies or pixels to use this Website.
You can manage website cookies in Your browser settings, and You always have the choice to change these settings by accepting, rejecting, or deleting cookies. All browser settings are slightly different, so to manage cookies, You should refer to the relevant settings within Your browser.
If You choose to change Your settings, You may find that certain functions and features will not work as intended for the Services or on Our Website, or the use of Our Website and Services might be more cumbersome and less accessible.
● Log Files
We may gather certain information automatically and store it in log files. This information includes the internet protocol (IP) address, browser type, internet service provider (ISP), and clickstream data. We do this to improve Our Services and Website, marketing, analytics or site functionality, and to authenticate users and clients.
● Do Not Track Signals
Some browsers or other tools include “do not track” features which, when turned on, send a signal to websites You visit indicating You do not wish to be tracked across websites over time. At this time, Beagle does not respond to these types of “do not track” signals.
● Social Media Features
● Third-Party Links
Our Website or Services may contain links to and may be used by You in conjunction with third party websites, apps, services and tools, and other information and advertising, none of which are affiliated with, or controlled, managed or endorsed by Us in any way.
The privacy practices of all such third-party information, services and websites (including those of Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers and AWS) may significantly differ from those of Beagle and will be governed by those parties’ own privacy policies.
Beagle is not responsible for the privacy practices, collection, use or disclosure of information, or the content of such websites or for the privacy and security policies and practices of such third parties.
You should review the privacy policies applicable to all such third-party websites.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use these “Email Marketing Providers” to manage and send emails to You, such as Mailchimp or AWS.
These Third-Party Remarketing Vendors collect, store, use, process and transfer information about Your activity on Our Services that enable Us to:
- Measure and analyze traffic and browsing activity on Our Services
- Show advertisements for Our products and/or services to You on third-party websites or apps
- Measure and analyze the performance of Our advertising campaigns
Some of these Third-Party Remarketing Vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies.
You can use the following third-party tools to decline the collection and use of Your information for the purpose of serving You interest-based advertising:
- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help sections for more information.
We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Services with these Third-Party Remarketing Vendors. This allows such vendors to recognize and deliver You ads across devices and browsers.
The Third-Party Remarketing Vendors We may be currently using are listed below, including information about their privacy policies, HOWEVER, please note that the information may become inaccurate through updates by these vendors, so it is best that You go directly to each such vendor’s website to review ALL privacy-related concerns You may have.
- Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for Your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
Please visit the Google Privacy & Terms web page at https://policies.google.com/privacy
- Bing Ads Remarketing
Bing Ads remarketing service is provided by Microsoft Inc.
You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-Us/resources/policies/personalized-ads
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/ or opt-out using Your mobile device settings.
Please visit the Facebook Data Policy web page: https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the Do Not Track functionality of Your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
AdRoll remarketing service is provided by NextRoll, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false or the Opt Out of Personalized Advertising web page: https://help.adroll.com/hc/en-Us/articles/216599538-Opting-Out-of-Personalized-Advertising
- Perfect Audience
Perfect Audience remarketing service is provided by NowSpots Inc.
AppNexus remarketing service is provided by AppNexus Inc.
You can opt-out of AppNexus remarketing by visiting the Privacy & the AppNexus Platform web page: https://www.appnexus.com/platform-privacy-policy
AppNexus remarketing service is provided by TikTok Inc.
Please also review their Cookies Policy at: https://www.tiktok.com/legal/cookie-policy?lang=en
AppNexus remarketing service is provided by Snap Inc..
Please visit the Privacy Center web page at: https://snap.com/en-US/privacy/privacy-center
HOW DO WE SECURE YOUR PERSONAL INFORMATION?
Beagle takes data security seriously, and We use appropriate technologies and procedures to protect Personal Information within Our company’s control. Our information security policies and procedures are closely aligned with industry standards and are reviewed regularly and updated as necessary to meet Our business needs, changes in technology, and regulatory requirements. Where appropriate, We password-protect, use encryption techniques and install firewalls.
We limit access to your Personal Information to only Our staff with authorized access who need to know the information in order to perform their jobs, and We require Our Third-Party Service Providers who perform services directly for Us (excluding Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers and AWS) to agree to keep your information confidential.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Please be aware that We cannot ensure or warrant the security of any information that You transmit to Us, or that We transmit to You, or guarantee that it will be free from unauthorized access by third parties.
Please also be aware that We may use third party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their systems, or they have a general reputation for applying such measures.
If You have reason to believe that Your interaction with Us is no longer secure, please immediately notify and contact Us at [email protected].
HOSTING SERVICES PROVIDER (AND DATA STORAGE) THROUGH AMAZON WEB SERVICES
We use and rely on the third-party data hosting services of Amazon Web Services, Inc. (“AWS”) to host Our Services on servers located in the United States. This means that if You do not reside in the U.S., then Your Personal Information and Other Information will be transferred out of Your country of residence and to the U.S., and such information will be processed and stored in the U.S.
AWS has represented to Us that the data protection and privacy practices they follow are in compliance with various relevant statutory norms. You can access details on this at http://aws.amazon.com/security/.
For users residing in the European Union, please note that AWS has established data protection policies and procedures in compliance with the GDPR. You can access details on this at https://aws.amazon.com/compliance/data-privacy-faq/. As previously stated, however, Our Website and Services are based in the U.S.
If You are not a resident of the U.S., by using the Services, by using or accessing Our Services in any way, You consent to the storage and processing of such information in the United States, which may have data protection laws that are different from those of your country of residence.
If You do not want your Personal Information to be transferred to a server located in the U.S., You should not provide Us with Your Personal Information or access or use the Service.
WHAT ARE MY OPT-OUT RIGHTS?
How do I access, change or delete my information or exercise my opt-out rights?
As part of Your use of Our Services or Website, You are responsible (when applicable) for maintaining and updating Your Personal Information with current, accurate and complete information. You may view, update or edit the Personal Information You have provided to Us by logging in to Your account and following the appropriate instructions. You can also request that We help You make such changes to Your Personal Information by contacting Us at [email protected].
You may opt-out from receiving marketing communications about Beagle products and services or periodic emails from Us by contacting Us at [email protected].
We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from Us, We may, if You are a client, still send You important administrative messages, from which You cannot opt-out.
Data Retention Practices
We retain Personal Information for as long as We deem reasonable for legal or business purposes, legal obligations or in accordance with applicable laws or court orders. In determining data retention periods, Beagle takes into consideration U.S. federal and state laws and contractual obligations. When We no longer need Personal Information, We securely delete or destroy it. Please note that Our Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers or AWS may have different data retention policies and procedures, so please refer to the applicable privacy policies for such information.
WHAT ARE MY PRIVACY RIGHTS UNDER THE CCPA IF I’M A CALIFORNIA RESIDENT?
If You are a California resident using the Services or visiting Our Website, You may exercise the following rights under the California Consumer Privacy Act (“CCPA”).
● Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information (as defined by California Civil Code §1798.83) collected, sold, or disclosed by Us; (2) purposes for which categories of Personal Information are collected or sold by Us; (3) categories of sources from which We collect Personal Information; and (4) specific pieces of Personal Information We have collected about You (if any) during the past twelve months.
● Right to Delete. Subject to certain exceptions, You may submit a verifiable request that We delete Personal Information about You that We have collected from You.
Please note that permanently deleting Your account with Beagle will erase all of Your Personal Information stored by Us and Our Third-Party Service Providers, but not necessarily Our Payment Processors, Other Third-Party Sources, Third-Party Remarketing Vendors, Email Marketing Providers or AWS. Consequently, You will no longer be able to use or access the Services (including certain Content) and Your account, and Your account and Personal Information will not be able to be restored or retrieved in any way.
● Right to Opt Out. In some circumstances, You may submit a verifiable request to opt out of Our renting, selling or sharing of Your Personal Information.
We do not rent, sell, or share Your Personal Information with other people or non-affiliated companies for their direct marketing purposes, unless We have Your permission. If We receive Your permission, non-affiliated companies may use Your Personal Information to send You offers or other information that You may find of interest. Notwithstanding the foregoing, We may share Personal Information about You with Our advertising partners (if any) in order to send You promotional communications about Our Services or to show You more tailored content, including relevant advertising for products and services that may be of interest to You.
If You wish to opt out of such information sharing, please send Us a verifiable request with Your request.
● Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of Your CCPA privacy rights, subject to applicable laws.
● Submit Requests. To exercise Your rights (as summarized above) under the CCPA, please send an email Your request to Us as noted in Our “How do You contact Us?” section below.
● Verification. Requests for access to or deletion of Personal Information, to exercise Your opt-out rights or for any other reasons related to Our Services or the Website are subject to Our ability to reasonably verify Your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations and any other applicable laws. To verify Your request, please follow the instructions provided in Our email response to Your request.
● Authorizing an Agent: To authorize an agent to make a request to know, access, opt-out or delete on Your behalf, please provide Us with written authorization signed by You and Your authorized agent, and We will contact You with further steps required to verify Your and Your authorized agent’s identities.
CALIFORNIA’S SHINE THE LIGHT LAW.
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits Our users and clients 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, as well as the names and addresses of those third parties. Requests may be made by You only once a year and are free of charge. See the “How do You contact Us?” section below if You wish to make such a request.
NO MINORS SHOULD USE OUR SERVICES.
Our Services are intended specifically for adults and not for children under 18 years old or the age of majority established under the applicable U.S. state law. Beagle does not knowingly collect Personal Information about children under the age of majority.
HOW DO YOU CONTACT US?
Because email communications are not always secure, please do not include any credit card or any other sensitive information in Your emails to Us.