PRIVACY POLICY
Last updated September 23, 2020
Thank you for choosing to be part of our community at Kitces.com (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected].
When you visit our website www.kitces.com, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.
This privacy policy applies to all information collected through our website (such as www.kitces.com), and/or any related services offered through this website (including speaking, consulting, research, and CE and other services through our Members Section, collectively referred to in this privacy policy as the "Services"). Notably, outside Kitces-related businesses, including XY Planning Network, AdvicePay, fpPathfinder, New Planner Recruiting, and FA Bean Counters, are not deemed part of the Services covered under this privacy policy, and your personal information is held separate and protected from any such related businesses.
Of course, if after reading this privacy policy to make an informed decision, there are any terms that you do not agree with or are not comfortable with, you can stop visiting Kitces.com and discontinue use of our services. But if you have such concerns, we hope that you’ll reach out to explore if there’s a way we can address your concern, first!
TABLE OF CONTENTS
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- What Information Do We Collect?
- How Do We Use Your Information?
- Will Your Information Be Shared With Anyone?
- Do We Use Cookies And Other Tracking Technologies?
- How Long Do We Keep Your Information?
- How Do We Keep Your Information Safe?
- Do We Collect Information From Minors?
- What Are Your Privacy Rights?
- Controls For Do-Not-Track Features
- Do California Residents Have Specific Privacy Rights?
- Do We Make Updates To This Policy?
- How Can You Contact Us About This Policy?
- How Can You Review, Update, Or Delete The Data We Collect From You?.
What Information Do We Collect?
Personal Information You Disclose To Us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information, along with information provided to us via various research surveys conducted through the Kitces.com platform.
We collect personal information that you voluntarily provide to us when registering for or participating in the Services, expressing an interest in obtaining information about us or our services, or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, and the choices you make about which services and features you use on this site.
The personal information we collect can include the following:
Personal Information Provided by You. We collect data on website usage; data collected from surveys; purchase history; and other similar data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Authorize.net in a PCI-compliant manner. You may find Authorize.net’s own privacy policy here: https://usa.visa.com/legal/privacy-policy.html.
All personal information that you provide to us is expected to be true, complete and accurate, and you can notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect devices; applications; tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics and marketing; device's geolocation; and other similar data.
How Do We Use Your Information
In Short: We use your information only to engage with Services on Kitces.com or Kitces-related businesses, but do not share any of your information with any outside Kitces-related businesses, nor with any advertisers or third-party vendors whatsoever.
We use personal information collected via our Services to further engage you, both with our Services, and other Kitces-related businesses. However, your personal information is never shared beyond Kitces.com and its Services, except in the case where required to comply with any legal or regulatory obligation.
Specifically, we use the personal information we collect or receive to:
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- Facilitate account creation and logon process. When you provide information to subscribe to our email list, or to join our Members Section. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we may use the information you allow us to collect from those third parties to facilitate account creation and logon process.
- Send you engagement communications. We may use the personal information you send to us for the purpose of further engaging you with our Services or Kitces-related businesses.
- Send administrative information to you. We may use your personal information to send you information about your use of our Services, new feature information, and/or information about changes to our terms, conditions, and policies.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
- Protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- Enforce our terms, conditions and policies for Business Purposes, Legal Reasons, and Contractual.
- Respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- Deliver services to the user. We may use your information to provide you with the requested service.
- Respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- Report Continuing Education credit (CE) to the appropriate agencies for certificates, including but not limited to the CFP Board, state Boards of Accountancy for CPAs, and the Investments and Wealth Institute (IWI).
- Analyze and publish research reports. We may use your information for advisor research purposes. However, any publishing or reporting of research results will be done only in an aggregated and anonymized form that is not associated with individual end users and does not include personal information.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our engagement, and to evaluate and improve our Services and your experience.
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Will Your Information Be Shared With Anyone?
In Short: No. Your personal information will only be used via Kitces.com to engage with our Services or Kitces-related businesses. We do not share any of your information with any outside parties, including Kitces-related businesses, except where necessary to comply with legal or regulatory obligations or to execute our contracted Services.
Your personal information will only be used on/via Kitces.com for the purposes of:
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- Engagement: We may process your data to further engage you with our Services and Kitces-related businesses but without sharing any information to Kitces-related businesses.
- Performance of our Services: Where you have entered into an engagement with us for Services, we may process your personal information to fulfill the terms of our engagement.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Your Employer: We may disclose your information to your employer if you are using your employer provided email address in association with Kitces.com and if your employer is paying for your account.
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and engagement efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. However, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly distributed outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
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Do We Use Cookies And Other Tracking Technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.
How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. Furthermore, any payment-related information is specifically held in third-party PCI-compliant systems and not on our services.
However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
Do We Collect Information From Minors?
In Short: We do not knowingly collect data from or try to engage children under 18 years of age.
We do not knowingly solicit data from or try to engage children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].
What Are Your Privacy Rights?
In Short: You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at [email protected].
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log into your account settings and update your user account.
■ Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
Opting out of email messaging: You can unsubscribe from our email list at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided below. You will then be removed from our email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
■ Contact us using the contact information provided.
■ Clicking unsubscribe in emails sent to you.
Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. Though as noted earlier in this privacy policy, your information is not shared with any such third parties in the first place.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
Do We Make Updates To This Policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
How Can You Contact Us About This Policy?
If you have questions or comments about this policy, you may email us at [email protected] or by post to:
Kitces.com
P.O. Box 2231
Reston, VA 20195
United States
How Can You Review, Update, Or Delete The Data We Collect From You?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.