Last updated April 4, 2024

We Respect Your Privacy

Before you dig through the legalese, we would like to make one thing clear: We do not rent or sell your personal information.

Looking for something specific but don’t want to dig through the legalese?

Email us at privacy@sigfig.com.

Last updated April 2024
Form ADV
Form CRS

Nvest, Inc. and its affiliates and subsidiaries, including SigFig Wealth Management LLC, (“we”, “our”, “us”or “SigFig”), are committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”) sets out our policies and procedures for collecting, using, maintaining, protecting and disclosing information provided to us by you when you access or browse SigFig.com, other Nvest, Inc. owned and/or operated websites, and certain SigFig-related services on our Partner (other financial institutions) sites, where we have access to your information (“Partner Sites”) (collectively, the “Sites”).

This Privacy Policy describes the type of information that we may collect for our own purposes through the Sites, how we use, protect, and share that information, and the choices and rights that you have. In some circumstances, we may receive or process personal information on behalf of a Partner’s client where we serve as a service provider to the Partner. This Privacy Policy does not describe all the information we may collect on behalf of or receive from our Partners and/or clients of Partners where SigFig operates as a service provider [or co-adviser or sub-adviser]. It also does not describe how we use, protect, or share that information. In those situations, the privacy policy of the Partner will apply.

This Privacy Policy applies to information we collect:

• On the Sites.
• In email, text and other electronic messages between you and us that are related to the services that we are providing you.
• Through our mobile and desktop applications, which provide other means of communication and interaction between you and the Sites. We may combine the information collected on the Sites or through mobile application or other function with information collected from or about you in other contexts.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy governs your use of our services and by accessing or using the Sites you agree to this Privacy Policy and you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. If you do not agree with our policies and practices, it means you have chosen to not use the Sites. For purposes of compliance with the Gramm-Leach-Bliley Act (the “GLB Act”), this Privacy Policy shall serve as both your initial and annual “privacy notice” as defined under the GLB Act.

If you have any questions or concerns regarding this statement, you should contact us at privacy@sigfig.com.

Information Collected by Us

We collect user-submitted information by which you may be personally identified, such as name, email address, and by which you may be contacted online or offline with notifications related to the use of the services offered by the Sites and other information you may provide, such as your age, income, liquid assets worth and risk tolerance. We maintain information you submit in your profile on the Sites. We collect information from you when you send us feedback as well. Some information collected is not explicitly submitted by the user. Examples of such information include (but are not limited to): browser-type related information, IP address, requested URL, referring URL, and timestamp. See “Use of Cookies and IP Address” below. If you choose to use our portfolio tracker services, we also collect your external brokerage account login credentials provided by you and information about your holdings in those accounts for the purpose of providing the services.

The types of personal information that we collect and share depend on the product or service you use. We also may receive information about you that you authorize other parties to provide to us.

In addition, we may collect information provided by users who choose to open an investment advisory account with us, including but not limited to:

• Social Security numbers and financial account numbers;
• Account balances and transaction information;
• Identifiers and login information required by the provider of a third party financial account when you sync your account to our Sites, such as your username and password, or a security token;
• Income, tax, assets and employment information;
• Birthdate;
• Physical Address;
• Email Address;
• Marital Status;
• State or Federally-Issued Identification (Driver’s License/Passport);
• Information about your beneficiaries and/or trusted contacts;
• Salary; and
• Contact Information.

(collectively, “personal information”).

Also, if you sync your brokerage account(s) and/or bank account(s) to the Sites, you may be required to direct SigFig to retrieve your own information maintained online by third party financial institutions with which you have customer relationships, maintain accounts or engage in financial transactions (“Account Information”). We will then connect directly with your online financial service providers to access this Account Information and facilitate financial transactions that you initiate through the Sites. SigFig may also work with one or more third party financial service technology providers (“Service Provider”) to access and retrieve your Account Information. Your financial institution may provide us with information about you and your account to facilitate our ability to provide our services to you and to reduce the amount of data you need to enter. If you have linked external accounts and ultimately close your portfolio tracker and/or investment advisory account with SigFig, SigFig may continue to have access to the data from those external accounts unless action is expressly taken to terminate the connections. Some of this data may be maintained or stored by SigFig in line with its obligations under the federal securities laws and internal policies, which generally call for retention for a minimum of five (5) years. The period of retention may vary depending on regulatory requirements, when and if the individual has (and ultimately closes) an investment advisory account, and other circumstances that deem it necessary to retain the data.

We keep records of our services, which may include but are not limited to, records of the advice that we provide to you, your use of our services, and your communications to us about our services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Sites and its contents to you;
• To provide you with information, products or services that you request from us;
• To market, personalize, develop and improve our products and services;
• To fulfill any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Sites or any products or services we offer or provide through our Sites;
• To respond to your feedback or inquiries;
• In any other way we may describe when you provide the information; and
• For any other purposes with your consent.

Your personal and investment information is maintained by us in order to provide you with customized investment and other services and to fulfill our legal and regulatory requirements. In addition, for users who elected to open a SigFig investment advisory account, we use the collected information primarily to:

• Facilitate opening an account with an independent brokerage and custodial firm (“Broker-Dealer”);
• Creating, implementing and continuously managing your investment portfolio strategy aligned with the investment preferences specified by you;
• Provide the Broker-Dealer with information required to provide ongoing wealth management services to you; and
• Provide you with notifications related to your investment advisory account and our wealth management services.

Data that does not include personal information may be used for research purposes. For instance, we may compile data, excluding personal information, for purposes of demographic analysis and research.

Service-related Announcements

We will send you service-related announcements on occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Use of Cookies and IP Addresses

As you navigate through and interact with the Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including browser-type related information, IP address, requested URL, referring URL, timestamp data, and other information to help us diagnose problems with our servers, administer the Sites, and otherwise provide the services to you. In addition, we may use this non-personal information to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Sites.

Like most websites, the Sites require cookies to function properly. Cookies are small text files that reside on a user’s computer and identify you as a unique user. We use cookies to refine our services and simplify the user experience. For example, the use of cookies allows registered users to enter the Sites without explicitly typing in their email address and password every time, and it allows us to personalize your experience on the Sites by allowing functions such as showing you your account balances. For these reasons we tie personal information such as your email address to our cookies. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies might be necessary to provide you certain features (e.g., customized delivery of information) available on the Sites.

We use tracking utility companies that use cookies and Web beacons on the Sites. We have no access to or control over these third party tracking utilities. For example, we use cookies in conjunction with Google Analytics Demographics and Interest Reporting in order to better understand our visitors. Google Analytics collects information such as how often users visit the Sites, what pages they visit when they do so, and what other sites they used prior to coming to our Sites. We use the information we get from Google Analytics only to maintain and improve the Sites. Google Analytics does not collect your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. As related to Google Analytics, visitors can choose to opt out using Ads Settings, Ad Settings for mobile apps, or any other available means including Google Analytics’ opt out tool. Unlike Google Analytics, not all tracking utility companies allow users to opt-out. If you do disagree with our use of cookies as set forth in this section, it means you have chosen not to use the Sites.

Partner Sites and Advertising

If you use the Partner Sites, we may share certain information about you with our Partners, such as “top ticker” data and watchlist holdings, which allow the partners to personalize your experience on the site or their mobile apps. We may also share aggregate data with Partners (without any of your personal information) to aid in monitoring the effectiveness of our product. Such data could include engagement and retention rates with our services, periodic usage metrics reports. Depending on the nature of the partnership (i.e. investment advisory account with a Partner), we may have access to or share other personal information with the Partner in the ways described above to provide the advisory or portfolio tracking services.

Please refer to our Partners’ privacy policies for more information about how they handle your data and information, including any personal information.

Unless we have your express permission, we will not share any personal information about you with any advertising companies or with the providers of the advertised goods and services, and these companies will not collect such information on our behalf. If you choose to use these separate goods and services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies.

Disclosure/Transfer of Information

Some of the information you provide on the Sites is publicly exposed in an aggregated and/or anonymized manner unless otherwise noted. However, except as set forth in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information. We do not share your personal information for a third parties’ promotional use without your express consent. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our Partners, subsidiaries and affiliates;
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• We will disclose information about individual users to governmental or judicial authorities or law enforcement agencies, or to other individuals or entities, in response to subpoenas, court orders, or other legal processes or regulatory requests. Further, we may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the terms and conditions of this Privacy Policy;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• To enforce or apply our Terms of Use; and
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or the rights, property or safety of our customers or others.

We reserve the right to transfer your personal information in the event of a transfer of our ownership, such as a restructuring, an acquisition by or merger with another company. In such an event, we will notify you before information about you is transferred and becomes subject to a different privacy policy. For the users who chose to open an investment advisory account with us, the transfer of personal information in the event of a transfer of our ownership is governed by the Investment Advisory Agreement between us and such users.

We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to communicate an objection to such information sharing.

Security

We have implemented measures and controls designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Our security measures include industry standard technology and equipment to help protect your personal information.

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 the Sites, you are responsible for keeping this password confidential. We ask you to not share your password with anyone and please be sure to not choose a password which you have used on other sites.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your personal information transmitted to the Sites. Any transmission of personal information is at your own risk.

You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet or the circumvention of any privacy settings or security measures contained on the Sites, and you hereby release us from any and all claims arising out of or related to such interceptions of information or circumventions of our Sites.

Customer Preferences and Opt-out Choices

We may also use your information to contact you about our services that may be of interest to you. If you do not want us to use your information in this way, please provide notice to us through one of the following ways:

• Adjust your user preferences in your account profile; or
• To opt-out of receiving promotional or marketing communications from us at a specific address, you may:
• • Use the unsubscribe instructions sent by us.
  • Or Contact us by mail or phone at:
    Nvest, Inc.
    2443 Fillmore Street, #380-1512
    San Francisco, CA 94115
    (855)-9SIGFIG
  • Note: It may take up to ten (10) business days to process your request post receipt of the request.

Accessing/Updating/Deleting Personal Information

Should you want to update your personal information, or to request assistance with accessing, correcting or deleting any personal information included in your account, please email support@sigfig.com. We will try to respond to your request promptly, but no later than within thirty (30) days of receipt of such request. We may not accommodate a request to change information if we believe the change would violate any law or legal or regulatory requirement or cause the information to be incorrect. We cannot delete individual personal information for you, but can do a wipe of a user’s personal information upon request. Please note, however, that even if we close your account or wipe a user’s personal information, we may retain and use certain of your information as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

Respecting Children’s Privacy

The Sites are not directed to children, and we do not knowingly solicit information from any child under the age of 13. If you are under the age of 13, do not use or provide any information on the Sites or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If a parent or guardian becomes aware that his or her child has provided us with personal information without his or her consent, he or she should contact us at privacy@sigfig.com. Should a child whom we know to be under 13 send personal information to us, we will delete it as soon as possible..

Your Privacy Rights

In certain circumstances you may have the following rights in relation to the processing of your personal information:

• Access Request
  To request a copy of the personal information we process in relation to you including: (i) the categories of personal information we collected about you and the categories of sources from which we collected the personal information; (ii) the business or commercial purpose for collecting the personal information about you; (iii) the categories of third parties to whom we disclosed personal information and the categories of personal information disclosed; and (iv) the specific pieces of personal information we collected about you.
• Deletion Request
  To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
• Objection Request
  To object to the processing of your personal information if: (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) we are processing your personal information for direct marketing purposes.
• Correction Request
  To request that we update the personal information we process in relation to you, or to correct personal information that you think is incorrect or incomplete.

You may exercise these rights by contacting us in the manner established herein. To the extent permitted by applicable law or regulation, we reserve the right to charge an appropriate fee in connection with certain requests submitted by you.

We may need to request specific information from you to help us confirm your identify and ensure your right to access to the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us locate the personal information processed in relation to you, including, for example, the nature and location of your relationship with us.

We aim to respond to all legitimate requests within thirty (30) days of receipt of such requests. If we think it may take us longer (such as where your request is particularly complex or you have made a number of requests), we will attempt to notify you and keep you updated.

Links

The Sites may contain links to third party websites to which we have no affiliation. The links are provided on the Sites solely for your convenience and may assist you in locating other useful information on the Internet. Unless you expressly authorize us to do so, we will not share your personal information with such third party websites. These third party websites are not under our control. In using such third party websites please be aware that each third party website is subject to its own privacy policies and is not covered by our Privacy Policy. We make no representation or warranty regarding the accuracy of the information contained on such third party websites, and we disclaims all responsibility relating to or resulting from your use of such third party websites.

Frames and Partner Sites

The Sites utilize framing techniques to allow users to access content from the Sites, when the user is actually on a third party website. We do this so that you will have a more seamless experience on the third party site. Regardless of our framing techniques, the third party and its website will remain visible and fully accessible, and will be governed by the privacy policy of the third party site, which will appear on those pages.

Conversely, the Partner Sites may appear on our partners’ websites but may actually be offered or hosted by us. The Partner Sites will be clearly marked with our name, and your use of them will be governed by this Privacy Policy.

Modifications to the Privacy Policy

This Privacy Policy may change from time to time. If we make a change to this Privacy Policy that we believe materially impacts your rights, we will provide you with prominent notice on our Site’s home page or by other means of notification. By continuing to use our services after those changes have become effective, you agree to be bound by the revised Privacy Policy. The date this Privacy Policy was last revised is identified at the top of the Page. You are responsible for periodically visiting our Sites and this Privacy Policy to check for any changes.

SigFig is also subject to certain regulatory requirements for distribution of a privacy policy or notice to investment advisory clients.

Contact

If you wish to make any requests, or have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an email to privacy@sigfig.com.

Nvest, Inc.
2443 Fillmore Street #380-1512
San Francisco, CA 94115
Phone: (855)-9SIGFIG

Form ADV
Form CRS