Privacy Policy

01Introduction

This Privacy Policy describes the ways Plural Everything Inc. and its affiliated firms (collectively, “we,” “us,” “our,” or “Plural”) collect, use, share, and protect information about you. By accessing or using any of our websites, mobile applications, other online or downloadable products and services, or offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (each a “Service” collectively, the “Services”), visiting our offices or facilities, or doing business with Plural, including but not limited to acting in your individual capacity or as an employee, owner, director, officer, or contractor of a company (collectively, “Business Contacts”), you agree to the practices described in this Privacy Policy regarding our collection, use, sharing, and protection of information about you.

We also include specific disclosures for residents of California - see “Your California Privacy Rights” below.

02Personal Information We Collect

There are two primary ways we collect information about you: (1) when you voluntarily provide it to us while using the Services or acting as a Business Contact; and (2) with automatic technologies connected to the Services. We explain this in further detail below in the sections titled “Information You Provide to Us” and “Information We Automatically Collect.”

This section describes the categories of personal information we may collect or may have collected from or about you, and the purposes for which this information is used.

Information You Provide to Us

03How We Share Information About You

We may share information we collect about you with entities, including business partners and affiliates, services providers, and third parties:

• Business Partners and Affiliates: We share your personal information with business partners with whom we work with, such as our affiliates and other companies that help us improve, market, or provide our services to you.
• Service Providers: We may permit our agents, vendors, consultants, and other service providers to access information we collect about you through the Services to carry out work on our behalf.
• Third parties: We may disclose information about you to third parties: (1) if we are required to do so by law, regulation, or legal process (such as in response to a court order or subpoena); (2) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; or (3) in the context of a business negotiation or transaction relating to Plural or any affiliated entity (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.

04Use of Cookies and Similar Technologies

We use cookies, web beacons, or similar technologies to collect information through data analytics tools like Google Analytics and other third-party tracking pixels to improve your site experience, to serve you better ads on other sites, and to track your activity over time and across websites, as well as across different devices you use to access the Internet. We may use information collected this way to target marketing we believe corresponds to your interests within and outside our Services, for example, by utilizing retargeting or other targeted marketing practices (collectively, “Online Behavioral Advertising”).

When engaging in Online Behavioral Advertising, we follow the cross-industry Self-Regulatory Principles for Online Behavioral Advertising managed by the Digital Advertising Alliance. To learn more about Online Behavioral Advertising, your choices regarding the information collected for that purpose, or to opt out, you may visit http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.

If you choose to opt out of Online Behavioral Advertising, a cookie will be placed on your browser indicating your choice. Because cookies are stored by your browser, any opt out choice you make will be effective only for the computer/browser combination you used to opt out. Please note that even if you opt out of Online Behavioral Advertising, you may still receive advertisements from us, but they will not be customized based on your online browsing activities. Clearing your browser's cookies will reset your opt out instruction because the instruction is stored in a browser cookie. If you were to clear your browser cookies, you would need to renew any opt out choice you previously made.

Many web browsers provide options to allow you to stop accepting new cookies, or to disable existing cookies. Please be aware that if you disable cookies on your browser, you may not be able to use certain features of the Services or other websites, and disabling cookies may invalidate opt-outs that rely on cookies to function.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

05How We Respond to Do Not Track Signals

Your internet browser may offer what is referred to as a “do not track” configuration that allows your browser to automatically signal your privacy preferences to certain websites that you visit. Industry standards related to this technology continue to evolve, and we have not yet identified a consensus on how to respond to such signals. Therefore, our websites do not currently respond to the “do not track” signals issued by browsers.

To learn more about “do not track” signals, you may wish to visit http://www.allaboutdnt.com/.

06Updating and Correcting Your Personal Information

Keeping your information current is important. If you are a customer of an affiliated broker-dealer in the Plural network, you may update, correct, or delete contact information by contacting your financial professional. If you are a customer or a financial professional who has enrolled in online Services with Plural or one of its affiliates, you can access your profile, review contact information that is stored, and revise certain types of information by signing into your online account. To make any other updates, customers should contact their financial professionals, and financial professionals should contact their Plural-affiliated broker-dealer. Business Contacts should contact their Plural business owner.

07Your Choices

As a consumer or customer of a Plural-affiliated broker-dealer, you can learn more about how and why we share information about you and your options related to such sharing by reviewing the broker-dealer's Consumer Privacy Notice (“Notice”), available below:

Federal law gives consumers and customers, as those terms are defined in the Gramm-Leach-Bliley Act (“GLBA”), the right to limit some but not all sharing of their information by financial companies like Plural. As explained in the Notice, you may opt out of sharing by calling the number provided in the Notice and following the prompts. (Please see the “To Limit Our Sharing” section in the Notice for instructions.) Your request will be addressed, but you will not receive a confirmation. Please note that customers will continue to receive annual Notices as required under Federal law; however, you do not need to respond to maintain a previous opt-out designation.

08Unsubscribe Information

If you would like to unsubscribe from marketing emails sent by Plural, you can do so by clicking the unsubscribe link included in the footer of our emails. Please note that even if you opt out of receiving such communications from us, we may continue to send you transactional emails, such as communications regarding your account or our ongoing relationship with you.

09Links to Affiliate and Non-Affiliate Websites

You should be aware that linked sites may have their own privacy policies or notices that differ from this Privacy Policy. Your use of linked sites is governed by the privacy policies and terms and conditions of those sites, which we strongly suggest you review.

10Children's Privacy

We do not knowingly collect personal information from children under the age of 16 through our Services, and we do not knowingly market to children under the age of 16 without parental consent. If we learn that we have received information directly from a child who is under the age of 16, we will delete the information in accordance with applicable law.

11Security

We employ administrative, technical, and physical safeguards to secure personal information. Plural's Information Security Program is designed to allow our representatives to use the tools and software we provide with confidence. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of information collected through our Services.

12Your California Privacy Rights

This section describes your rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

Under the CCPA and CPRA, “Personal Information” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” As a financial services organization, any information we collect, process, or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102) or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code) is exempt from the requirements of CCPA and CPRA. In addition, some information we collect may be exempt because it is considered public information (i.e., it is made available by a government entity) or because it is subject to other federal privacy laws, such as the Health Insurance Portability and Accountability Act.

To the extent that we collect Personal Information that is subject to the CCPA and CPRA, your rights as a California resident to request access, correction, and deletion of that information are described below.

Plural does not “sell” or “share” your Personal Information as those terms are defined by CCPA and CPRA; however, we may share your Personal Information for the purposes of targeted advertising, which under CCPA and CPRA, may be considered a “sale.” We provide details below regarding how you can opt-out of such sharing or “selling.”

Description of Your Rights

Subject to certain limitations, you have the following rights with respect to your Personal Information.

• Right to Know/Access Information - You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months with respect to the following:
  • The categories of Personal Information we collect about you.
  • The categories of sources for the Personal Information we collect about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of Personal Information being collected about you.
• Right to Request Deletion of Information - You have the right to request in certain circumstances that we delete Personal Information that we have collected directly from you. It should be noted that we may not be able to delete certain Personal Information due to business, regulatory, legal, and compliance purposes. In addition, deletion of your Personal Information may affect our ability to provide services, products, and support to you.
• Right to Correct - You have the right to request that we correct inaccuracies in the Personal Information we collect about you.
• Right to Opt-Out of the Sharing of Your Personal Information - You have the right to request to be opted out from the sale or sharing of Personal Information for the purposes of targeted advertising.
• Right to Limit Use/Disclosure of Sensitive Personal Information - You have the right to limit the use/disclosure of your sensitive Personal Information.
• Right to Non-Discrimination - You have the right to not be denied goods or services, charged different prices or rates for goods or services, or receive a different level or quality of goods or services, as a result of exercising the above rights.

How to Submit a Request

You may submit a request to exercise your California privacy rights through any one of these means:

• By calling us at +1 415 569 7991 or emailing us at privacy@pluralfinance.com

Verification Procedures - In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by requesting that you provide personal identifiers that we can match against information we may have collected from you previously. We may also request you to confirm your request using the email or telephone account stated in the request.

Requests by Authorized Agent - You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you provide legal documentation confirming the identity and authority of an authorized agent to act on your behalf. Such documentation may include, but is not limited to, a power of attorney, conservatorship or guardianship documentation, letters testamentary, or notarized statements (as may be appropriate under the circumstances). Parents of minor children may be required to submit a birth certificate of the child, in order to make requests on the child's behalf.

13Retention of Personal Information

We retain your personal information in accordance with our record retention schedules and policies. Personal information is retained as long as necessary to meet business, legal, and regulatory requirements. Retention may be extended in connection with litigation or investigations.

14Changes to this Privacy Policy

If we make changes to this Privacy Policy, we will revise the ”Last Updated” date at the top of this page. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the applicable Service. Your use of such Service following these changes means that you accept the revised Privacy Policy.

15Contact Us

For any questions you may have regarding this Privacy Policy, other than to opt out (please see the “Your Choices” section above for information on opting out), you have several options for reaching us. You may email us at privacy@pluralfinance.com, phone us at +1 415 569 7991, or write to us at the following address: